1984 Agency
United States Office of Water
Environmental Protection Washington. DC 20460 June 1984
&EPA Monitoring Strategy
Office of Water
OOOR84002
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MONITORING STRATEGY
OFFICE OF WATER
Jack E. Ravan
Assistant Administrator
Office of Water
U.S. Environmental Protection Agency
Washington, D.C.
Compiled by the
Monitoring and Data Support Division
Office of Water Regulations and Standards
June 15, 1984
Protection /ge
ibrary (5PL-16)
jcrn Street, Room 1670
60604
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE OF
WATER
June 15, 1984
MEMORANDUM
SUBJECT: Transmittal of the Office of Water Monitoring Strategy
FROM: Jack E. Ravan <^K>^
Assistant Administrator for Water (WH-556)
TO: Alvin L. Aim
Deputy Administrator (A-101)
Attached is the final Office of Water (OW) Monitoring
Strategy prepared in response to the Agency's Environmental
Monitoring Policy.
This OW Monitoring Strategy contains individual program
strategies for Inland and Coastal Waters, National Pollutant
Discharge Elimination System Compliance, Oceans, and Drinking
Water. It sets the course for future OW monitoring activities
and updates the monitoring program to reflect new objectives,
information needs, and technologies. We are also including an
issue paper on ground-water monitoring.
We are continuing to review this strategy within the
Office of Water in terms of the FY86 budget process. Also,
because we depend heavily on the outputs of other program
offices to ensure the success of OW activities, we are working
with these offices to cross-walk activities. We specifically
refer to the Office of Research and Development where it is
critical that their outputs, such as section 304(h) methods, be
produced at a rate consistent with OW program needs.
Attachment
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This environmental monitoring strategy was developed in
response to the Agency's Environmental Monitoring Policy. This
strategy will be reviewed and updated annually. The update will
be completed by May 25 of each year. Comments from both inside
and outside EPA are welcomed any time and will be considered in
the update. Comments should be submitted to:
U.S. Environmental Protection Agency
Office of Water
Monitoring and Data Support Division (WH-553)
401 M St. SW
Washington, D.C. 20560
Attn: Thomas M. Murray
(202) 382-7056
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CONTENTS
OW MONITORING STRATEGY OVERVIEW
INLAND AND COASTAL WATERS
NPDES COMPLIANCE
OCEANS
DRINKING WATER
DRAFT GROUND-WATER MONITORING ISSUE PAPER
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OVGRVieUU
Office of mater Monitoring Strategy
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OFFICE OF WATER
MONITORING STRATEGY
OVERVIEW
The programs administered by the Office of Water have
changed dramatically during the last decade. In the past, the
water quality program focused on a small number of well-known
pollutants such as nutrients, BOD/dissolved oxygen, and total
suspended solids. Similarly, the drinking water program focused
on inorganic compounds and bacteria in streams, and bacteria,
turbidity, and inorganic contaminants in finished drinking water.
Although it was recognized that other pollutants such as metals
and synthetic organics might be a problem, for a number of reasons
these pollutants generally could not be regulated. These reasons
included the lack of suitable methods for measuring and regulating
many of these pollutants, and the lack of data on the health and
environmental risks associated with them.
In the last decade, however, there has been an emphasis on
establishing statutory and regulatory controls, such as the 1977
amendments to the Clean Water Act and the Safe Drinking Water
Act, to address these additional pollutants. This emphasis is
expected to continue because only a few of the approximately
50,000 chemical compounds in commercial use today are monitored
in the environment or have been tested for toxicity or environ-
mental effects. Because the statutory and regulatory controls
on these additional pollutants have been in place for several
years, it is time to update our monitoring program to reflect
our experience in administering these new programs.
A variety of activities and support functions designed to
update our monitoring program are discussed in each of the
individual program strategies that comprise the Office of Water's
Monitoring Strategy. Each such activity or support function
specifically addresses the needs of its particular program;
however, a common bond exists among these activities. For
each, EPA must ensure that it is collecting the right kinds and
amounts of data, that the data are reliable, and that the data
are accessible to decisionmakers and other users. These
considerations are discussed below. Also discussed are the
new technologies that affect these data collection and handling
considerations, and that are becoming available to EPA through
the latest developments in the fields of automated data processing,
remote sensing, automatic monitors, data telemetry, and biotech-
nology. These technologies are also discussed in more detail in
Section 2 ot the OWRS Monitoring Strategy for Inland and Coastal
Waters. As we shall see, the challenge of the 1980"s is to get
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new monitoring and information technologies "off the shelf"
and into the field, and in so doing to modernize our monitoring
programs for surface water, drinking water, and ground water.
I. Ensuring the collection of the right kinds and amounts of data.
The Office of Water must collect data for new parameters
such as toxics and expand the use of bioassays and biosurveys,
as well as continue to collect data for traditional parameters
such as dissolved oxygen, bacteria, and inorganics. Monitoring
for new parameters is needed to provide early warning of problems
(thus minimizing the need for "crisis management") and to develop
needed controls. In the drinking water program, for example,
monitoring for new parameters is an ongoing activity; the number
of new chemicals being found, and their increased frequency of
occurrence, indicate the need for additional surveys.
At the same time, continued monitoring of traditional
parameters is needed to control remaining water quality problems.
Virtually all of the water quality problems addressed through
the construction grants program, for example, involve routine
parameters.
As a key initiative in this area, the Office of Water is
emphasizing additional targeted toxics monitoring for surface
waters and drinking water supplies. This will include expanded
use of bioassays and biosurveys in screening and controlling
industrial and municipal discharges. These data are needed to
better determine the magnitude and extent of toxics pollution;
we can then focus our efforts on developing priority control
requirements to improve the quality of these waters.
The Office of Water also expects to place more emphasis on
ground water data. This will include assessing existing data
resources and making them more accessible to managers at all
levels of government, as well as judging the need for additional
data to determine ground water quality and the extent and sources
of ground water contamination. The Office of Ground Water
Protection will assess ongoing data collection efforts and,
working with the U.S. Geological Survey and others, will develop
a ground water monitoring strategy by Spring, 1985.
Other initiatives include a review of the amounts and kinds
of data collected in the oceans program to ensure the appropriate
balance between biological, chemical, and physical data; and major
surveys of inorganics, radionuclides, and pesticides in drinking
water.
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II. Ensuring that the monitoring data are reliable.
The quality of decisions depends largely on the quality of
the data used in making those decisions. Ensuring the reliability
of monitoring data involves a variety of quality assurance/quality
control activities such as: using documented QA/QC procedures;
labeling data sets as to quality; setting up procedures in data
systems for filtering out poor quality data and locating data
gaps; and ensuring that appropriate sampling plans are used.
As our key initiative in this area, the Office of Water will
place additional emphasis on ensuring that all data used in the
water programs are of known and suitable quality. The individual
offices will be responsible for reviewing their present procedures
and developing plans for any needed changes. At a minimum, all
Offices will ensure that appropriate monitoring plans are designed
before data collection begins and that performance audits are
carried out at laboratories providing them with data. The
objective is to ensure that decisionmaking in the water programs
is based on suitable data and, more specifically, that users of
the data can readily determine which data sets are suitable for a
particular analysis.
Ill. Ensuring that the data are accessible to decisionmakers and
other users.
At present, large amounts of environmental data are of very
limited usefulness because they are not readily available for use
in decisionmaking. Data can be made accessible by integrating
existing data systems, adding needed existing data to these
systems, and developing analytical tools which provide fast and
accurate answers to EPA and State managers.
As a key initiative in this area, we are proceeding with the
linking of logically related data bases in the Office of Water,
and the further development of user-friendly tools for analyzing
these data. This will allow State, Regional, and National program
managers to quickly access and analyze data on ambient conditions,
source loadings and compliance, drinking water intakes, and
status of construction grants for a particular stream reach or
group of reaches. This effort includes developing ways to access
additional ocean monitoring data needed for the assessment of
ocean discharges, and crosslinking the Permit Compliance System
data with other data systems (such as those associated with
Resource Conservation and Recovery Act activities and underground
injection controls) in order to allow better assessments of the
water quality impacts associated with sources such as storage
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tanks, lagoons, and sludge. This will allow for better analyses
of water quality impacts in particular stream reaches, and will
provide additional data needed for developing ef'fluent limits
for permits.
New Technologies
Federal and academic research is continually supplying us
with new and improved ways of monitoring the environment, tele-
communicating data, and integrating and interpreting environmental
information. These new technologies include automated data
processing developments, and physico-technological and biotech-
nolonical develonments.
nological developments
Automated data processing developments include the use of
software that allows users to interactively retrieve, from
linked data bases, information that is relevant to their parti-
cular analytical needs. Examples include the River Reach File
(RRF) Routing and Graphical Display System (RGDS), and the
Industrial Facilities Discharge (IFD) file/RRF interactive
system, both of which are being pilot tested by the Office of
Water.
Physico-technological developments include the use of
aerial photography (to identify point sources, identify land use
and ecosystem characteristics, identify discharge plumes, locate
leaking septic tanks, and locate dischargers that have not
filed for permits); the use of hydrographic and land use infor-
mation in designing field surveys; and advances in gas chroma-
tography/mass spectroscopy (GC/MS) technology.
Biotechnological developments include the use of mobile
assay units for on-site laboratory analyses; the use of short-term
chronic bioassays in performing wasteload allocations and deriving
effluent limitations; the use of physiological and subcellular
biological methods to determine water quality changes and evaluate
environmental stress; and the use of rapid acute toxicity methods
as screens in identifying the presence or absence of toxicity.
We need to evaluate the role of these new technologies in
the water monitoring program. In our effort to meet the program
initiatives discussed above, OW will conduct a thorough review
of those technologies that are currently being pilot tested
and those that are sufficiently developed to be ready for
pilot testing, and, to the extent possible, will introduce them
into the monitoring program.
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Other technological developments are being tracked by the
Office of Water, but require additional research before they
can be considered for pilot testing. These include physico-
technological methods such as the use of automatic monitors to
analyze metals and organics and telecommunicate the results of
these analyses to field stations; and biotechnological methods
such as the use of fish rheotaxis and other behavioral phenomena
to rapidly detect acute concentrations of toxic substances in
surface water; the use of genotoxicological methods to measure
potential human health impacts; and the use of laser-based optical
systems for analyzing phytoplankton communities as indicators
of water quality. OW will work within the OW/ORD Consolidated
Water Research Committee to ensure that these developments receive
adequate attention. OW has worked with ORD to include, in an
ORD budget initiative, further research and development of high
technology methods.
In developing these initiatives, OW will also review the
equipment and training needs that must be met if we are to
effectively employ these new technologies in the water quality
monitoring program.
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INLRND RND COFISTRl UURT6RS
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INTRODUCTION
The OWRS monitoring strategy addresses three water quality
monitoring activities for inland and coastal waters: regulatory
monitoring; assessments; and program evaluation. It also discusses
monitoring program support functions associated with these activi-
ties, specifically, program oversight, quality assurance/quality
control, and data management. These topics are discussed indi-
vidually for simplicity; they actually function together as part
of a single monitoring system. Regulatory monitoring for assessing
compliance, enforcing permits, and developing water quality-based
controls for discharges to oceans and ground waters are not
discussed in this strategy document.
The strategy primarily addresses that monitoring program
which is designed to meet the requirements of the Clean Water Act.
Individual State needs falling outside of this scope are not
specifically discussed because they vary considerably from State
to State. However, these needs are important and must be addressed
using available resources. State needs are therefore considered
implicitly in the discussion of program resources and program
plans in Section 3 of the strategy.
This chapter is composed of two parts. Part I is the
water monitoring policy for inland and coastal waters. Part
II is the actual monitoring strategy and consists of seven sections
Section 1 lists the fundamental needs associated with key program
objectives and the extent to which these fundamental needs are
being met; Section 2 discusses technical barriers and opportunities
affecting our ability to meet these needs (these opportunities
generally reflect technological developments that are being consi-
dered for introduction into the water quality monitoring program);
Section 3 discusses monitoring resources and program plans to
ensure that fundamental needs are met; Sections 4-6 discuss
different factors, such as data management and linkages with
other programs, which play a key role in implementing the program
plans; and Section 7 is a schedule for implementating the strategy.
This strategy will be followed in FY84 by an updated Basic
Water Monitoring Program (BWMP) which will serve as a technical
support document that addresses specifically how the monitoring
activities expressed in this strategy will be conducted. The
revised BWMP will be completed by October 1984.
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PRRT I:
Water Quality Monitoring Policy
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MONITORING POLICY
INLAND AND COASTAL WATERS
PURPOSE OF THIS POLICY
The purpose of this policy is to establish overall goals and
objectives for those key elements of the water quality monitoring
program which are most needed to achieve the "f ishable/swinnmable"
goal of the Clean Water Act (CWA), implement applicable EPA
regulations, and implement the EPA Environmental Monitoring Policy.
Water quality monitoring is required by the Clean Water Act and
provides the data needed to regulate sources of water pollution,
assess the quality of the Nation's waters and evaluate the
environmental effectiveness of National water quality programs.
SCOPE OF THIS POLICY
"Water quality monitoring" is defined as the set of activities
which provides chemical, physical, geological, biological, and
other environmental data required by environmental managers. For
the purpose of this policy, water quality monitoring is limited
to those activities involved in the EPA and State implementation of
the Clean Water Act in inland/coastal waters. "Regulatory monitoring"
is the collection and analysis of effluent and ambient data needed
for establishing water quality-based permit requirements and for
assessing and enforcing compliance with permits. Regulatory
monitoring also provides data necessary for establishing water quality-
based controls for nonpoint sources. Regulatory monitoring for
assessing and enforcing compliance with permits is not addressed in
this policy.
STATEMENT OF POLICY
MAJOR OBJECTIVES; This policy establishes three major objectives for
the Nation's water monitoring program:
I. Advance the Regulatory Monitoring Program:
Regulatory monitoring for establishing and enforcing water quality-
based permit requirements and determining needed nonpoint source
abatement actions is the highest priority of this policy. The goal is to
strengthen the process for identifying waters not fully meeting designated
uses and provide comprehensive, reliable data to EPA Regions and
States for water quality management, construction grant and permit
decisions. Attention should be given to identifying new problems as
well as to controlling known problems.
In view of the need for regulatory monitoring data on sources of pollution
and impacted waters, EPA may require dischargers to collect chemical,
physical and biological data on their effluents and ambient conditions
in their receiving waters as a National Pollutant Discharge Elimination
System (NPDES) permit requirement. Ambient data requirements in
NPDES permits will be established, in consultation with the State
and the dischargers, when the potential exists for non-attainment of
water quality standards. EPA will also support State requirements
for data collection by dischargers.
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II. Conduct Sound Assessments:
Water quality assessments are defined as the analysis of
environmental data to determine the quality of the ambient
environment. Assessments are usually done for fairly large
geographical areas, such as States, and may use a number of
different kinds of data, e.g., concentrations of pollutants in
receiving waters, number of reported fish kills, and the amount of
impact detected in natural biological cormunities. Projections of
future conditions may also be done using detected ambient trends
and data on expected pollution loads.
National, regional and State assessments of water quality are
to be done at least every two years using, at a minimum, information
collected to meet the requirements of Sections 305(b) and 205(j)
of the CWA. On a six year cycle, beginning in 1988, the States
will submit long term trend information as part of their Section
305(b) Reports. To support these and other assessments, each State
will develop site-specific monitoring plans for waters not meeting
designated uses. These plans are to be developed following EPA
guidance and are to be negotiated between the Regions and the States.
The Office of Water will supplement the Section 305(b) information
to the extent necessary to derive sound national estimates and to
answer questions of immediate interest to program managers. Regional
assessments shall be performed as needed for Environmental Management
Reports. Additional assessments of specific water quality problems
will be performed on an as-needed basis. To the extent feasible,
data will be extracted from ongoing regional and State regulatory
monitoring.
III. Evaluate Control Programs:
EPA will utilize its formal program management and reporting
systems for guiding EPA and State water quality monitoring activities
and for evaluating EPA and State performance.
Program evaluation studies use water quality assessments to
evaluate the effects of pollution control programs on environmental
conditions. Program evaluation studies will be performed as needed
to evaluate the environmental results of major National programs.
To the extent feasible, data will be extracted from on-going Regional
and State regulatory monitoring studies.
PROGRAM SUPPORT FUNCTIONS; The following program support functions
must be accomplished if the major objectives are to be met:
Improving EPA Oversight of the States; EPA is required to provide
oversight of the States' implementation of the Clean Water Act. In
order to provide adequate oversight, the EPA must have adequate
information on both water quality conditions and pollution control
activities in each State. Therefore, all appropriate State water
quality data necessary to ensure implementation of the Clean Water
Act must be reported to EPA via entry into STORET or in STORET
compatible format. This includes appropriate assessment data;
appropriate screening data; and all regulatory monitoring data,
including data needed for approvals of water quality standards, and
wasteload allocations/total maximum daily loads.
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In addition, Regions must ensure that they have adequate
information on the water quality monitoring program in each State.
If a State's proposed work program for a Section 106 grant fails
to address a national priority monitoring activity that the Regional
Administrator considers essential, the Regional Administrator may
award an amount less than the allotment derived under the National
allocation formula until the State's work program shows that the
national priority activity is adequately addressed.
The individual State allotments derived from the national allocation
formula represent funding targets and are not individual State
entitlements. The funding targets are used to guide the development
of State work programs and serve as a basis of discussion between the
Regional Administrator and the State during negotiations over the
final work program. The actual grant award is based on these negotiations
between the State and Regional Administrator and is determined by
annual State program activities. The State and Regional Administrator
agree upon the State's annual activities and a funding level commensurate
with those activities. The Regional Administrator may determine that
a State's proposed activities do not represent a balanced water quality
management approach consistent with national priorities contained in
national and regional guidance. If a State work program does not
adequately address a priority activity contained in national and regional
guidance, the Regional Administrator may award less than the State's
initial funding allotment in accordance with 40 CFR 35.143(b).
EPA Regions will work closely with the States through the Section
106 program planning process to ensure that the combined efforts of
the Regions and States reflect national monitoring priorities and
support EPA regulations and policies.
Improving Data Quality; Quality assurance/quality
control will continue to be a high priority. The goal is that all
data used by EPA or States for decisionmaking will be of known and
sufficient quality for the intended uses. Also, for monitoring used
for national and Regional assessments, where feasible, the data should
be of comparable quality to allow for effective use of Regional and
National data bases.
Data Management: The goal is that data systems will be made more
useful so that EPA and State managers will be able to use ambient data
and assessments to determine the environmental impacts of decisions.
This will be accomplished by cross-linking existing data systems and
developing interactive data retrieval and analysis mechanisms usable
by line managers.
POLES OF THE EPA AND THE STATES IN IMPLEMENTING THIS POLICY
I. EPA Headquarters: Provide overall policy, guidance, technical
assistance and overview of program implementation by the Regions
and States. Specific responsibilities follow:
A. Prepare guidance and ensure that technical training and technical
assistance is available for monitoring, water quality analysis,
and data reporting.
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B. Perform national assessments and evaluate the national water
quality effects of CW& programs.
C. Make national data systems more useful for national, regional,
and state managers by upgrading and cross-linking the existing
systems and developing interactive data retrieval and analysis
mechanisms for line managers. Continue support of the River
Reach and Industrial Facility Discharge files.
D. Ensure that appropriate quality assurance/quality control
procedures are used in all national data collection efforts
and provide needed laboratory capability for national studies
of pollutants requiring special analyses, e.g., dioxin.
E. Prepare Headquarters budget requests, and in consultation with
the Regions, prepare requests for Regional and State water
quality monitoring and analysis programs.
F. Peer review major agency program activities involving water
monitoring and consult with other program offices on water
monitoring activities.
II. Regional Offices: Provide overall policy, guidance and overview
of program implementation by States. Provide oversight of the
States to ensure that adequate State resources from Sections
106/205(j) grants are directed to priority activities in monitoring,
water quality analysis, and data reporting. Provide technical
assistance and training for States. Ensure that needed water
quality-based controls are developed, and provide needed water
quality-based controls if the State fails to act in a timely
manner. Implement Section 106(e) requirement for adequate State
monitoring programs. Ensure that data are entered into national
data systems. Specific responsibilities follow:
A. Ensure that appropriate regulatory monitoring is performed by
States, the Region or dischargers needed for developing and
implementing water quality based-controls and identifying needed
nonpoint source controls. This includes data required to
identify waters needing water-quality based controls, data
needed to develop controls, and data needed to assess the
effectiveness of controls. Ensure that the developed controls
are implemented and provide controls if the State fails to
act in a timely manner.
B. Provide technical assistance and training to the States.
Ensure that each Regional Office has the capability to conduct
water quality monitoring and analyses. For work involving
toxics, where feasible the Region is expected to have a
capability in both the pollutant-specific and the biomonitoring
approaches.
C. Ensure that appropriate quality assurance/quality control
procedures are used for all Regional and State water quality
data and for all data used in regional decisionmaking,
including data reported by permittees.
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D. Perform regional water quality assessments, primarily based
on State data, as needed to prepare Environmental Management
Reports.
E. Ensure that regional data systems are compatible with and do
not unnecessarily duplicate national data systems. Ensure
that data collected by the States and the Regions are entered
into the national system, including data needed
to update the Industrial Facilities Discharge File.
III. States: Perform regulatory monitoring, assessments and program
evaluations as needed to meet the requirements of the Clean
Water Act. States have the primary responsibility for monitoring
and water quality analysis. In carrying out this responsibility,
States are expected to implement a balanced monitoring program.
Specific responsibilities follow:
A. As the first priority, States should collect and analyze data
as needed to make water quality management decisions:
1. Identify (a) waters not fully supporting designated uses and
(b) priority waterbodies, i.e., those waters most needing
water quality-based and nonpoint source controls or other
actions to prevent or reverse an impairment of the designated
use. Determine the reason(s) for nonsupport and the actions
needed to prevent or reverse the impairment of the use.
Include this information in the biennial Section 305(b)
Report to Congress. Focus on toxics as well as conventional
pollutants. Simple screening techniques may be appropriate
for many situations.
2. Develop needed water quality-based controls for both
conventional and toxic pollutants. For toxics, use both
the pollutant-specific and the biomonitoring techniques,
as appropriate.
3. As needed to supplement State and Regional regulatory
monitoring, write effluent and ambient data collection
requirements into permits for identifying waters needing
controls, developing controls, and assessing the
effectiveness of these controls to ensure the use is
maintained or restored.
B. Perform any additional monitoring needed for the Section
305(b) Report to Congress, including monitoring needed
to determine the status of waters not meeting designated uses
and the reason(s) for nonattainment.
C. Ensure that needed environmental data are provided to EPA,
including appropriate assessment data; appropriate screening
data; and all regulatory data including data needed for
approvals of water quality standards and wasteload
allocations/total maximum daily loads.
D. Ensure that appropriate quality assurance/quality control
procedures are used for all data used in State decisionmaking
and for all data reported to EPA, including data reported by
dischargers.
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PflRT II:
Inland and Coastal Waters Strategy
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MONITORING STRATEGY FOR INLAND AND COASTAL WATERS
TABLE OF CONTENTS
PAGE
SECTION 1 - WHAT ARE THE AGENCY'S MONITORING
OBJECTIVES AND INFORMATION NEEDS? 1
Objective I: Advance the Regulatory
Monitoring Program 1
Objective II: Conduct Sound Assessments 4
Objective III: Evaluate Control Programs 6
Program Support Functions 7
Improving EPA Oversight ....... 7
Improving Data Quality 7
Managing Data Systems 8
SECTION 2 - WHAT TECHNICAL BARRIERS AND OPPORTUNITIES
AFFECT OUR ABILITY TO MEET THESE NEEDS? . 9
Technical Barriers 9
Opportunities 10
SECTION 3 - WHAT IS THE MONITORING PLAN TO MEET THESE
NEEDS? 12
Objective I: Advance the Regulatory
Monitoring Program 12
Objective II: Conduct Sound Assessments 14
Objective III: Evaluate Control Programs 20
Program Support Functions 21
Improving EPA Oversight 21
Improving Data Quality 21
Managing Data Systems 22
SECTION 4 - HOW WILL WE IMPROVE OUR MONITORING
DESIGN? 23
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TABLE OF CONTENTS (cont'd)
PAGE
SECTION 5 - HOW WILL WE WORK WITH OTHER PROGRAMS
AND FEDERAL AGENCIES? 25
SECTION 6 - HOW WILL WE MANAGE DATA SYSTEMS? 27
SECTION 7 - WHAT IS THE SCHEDULE FOR IMPLEMENTING
THIS STRATEGY? 29
Schedule A: Completing the Monitoring
Strategy 30
Schedule B: Updating the Basic Water
Monitoring Program 31
Schedule C: Updating the OW/ORD Crosswalk ... 32
FIGURES
Figure 1: Major Elements of the Water Quality-
Based Standards-to-Perrait Process .... 2
Figure 2: Priority Waterbodies 12
TABLES
Table 1: Shortfall in Wasteload Allocations and
Intensive Surveys 3
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SECTION 1
WHAT ARE THE AGENCY'S MONITORING OBJECTIVES
AND INFORMATION NEEDS?
In order to meet the goals of the Clean Water Act, the
Agency's Environmental Monitoring Policy, and the Office of
Water's (OW) Monitoring Policy, the Office of Water Regulations
and Standards has developed a comprehensive water monitoring
strategy for inland and coastal waters. This strategy is designed
to improve the effectiveness of State and EPA monitoring programs,
reduce duplication of effort, define what is expected of EPA and
the States, and make best use of existing resources and technology.
OBJECTIVES
The Monitoring Strategy establishes plans and procedures for
meeting three basic monitoring objectives: to advance the
regulatory monitoring program; to conduct sound assessments; and
to evaluate control programs. In order to fulfill these objectives,
certain fundamental data needs must be met. These objectives
and their associated data needs, as well as brief discussions of
the extent to which these needs are being met, are presented
below.
Objective I - Advance The Regulatory Monitoring Program
Regulatory monitoring provides data for the establishment of
water quality-based permit effluent limits, and establishment of
water quality-based nonpoint source (NPS) controls. Unlike
monitoring for general water quality assessments and/or for
program evaluations, monitoring for developing water quality-
based controls and NPS impact determinations is focused on site-
specific conditions. It includes the normal range of activities
carried out by States and EPA in their water quality standards
and wasteload allocation/total maximum daily load (WLA/TMDL)
programs under Section 303 of the Clean Water Act. Figure 1
shows the steps involved in developing water quality-based
controls.
Data Needs:
Regulatory monitoring has traditionally been performed for
conventional pollutants to determine compliance of construction
grants projects and industrial facilities with permit limits.
Most permit limits have been technology-based, requiring secondary
treatment for municipal wastewater treatment facilities and Best
Available Treatment (BAT) or other limits for industrial facilities.
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FIGURE I: MAJOR ELEMENTS OF THE WATER QUALITY-BASED
STANDARDS-TO-PERMITS PROCESS
1: Identify water quality-limited (WQL) segments
• set control priorities
• implement local monitoring program, if necessary
2: Review and revise/reaffirm water quality standards
3: Develop water quality-based control requirements
4: Update water quality management plans with
• WQL segments and priorities
• TMDL's and effluent limits
• Feasible nonpoint source controls
Issue water quality-based permits,
Make water quality-based construction
grant decisions, and
implement nonpoint source controls
6: • Monitor municipal/industrial sources for compliance
• Perform ambient monitoring to document protection
of designated uses
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Increasing numbers of water quality-based permits are now being
issued. These permits go beyond technology based controls and
may involve both toxic pollutant and nonpoint source controls.
A number of data needs must be met, however, to improve these
controls. For example:
o Many States need formal programs for identifying and
setting priorities for waters needing water quality-based
controls.
o More States need to develop a greater number of water
quality-based limits for toxic pollutants and for
small dischargers.
o Where water quality-based limits are developed, controls
are generally limited to BOD/DO (and, in some cases,
nutrient and ammonia limits) for construction grant
projects and selected major industrial permits. Controls
are needed for minor dischargers or as part of a basin-
wide approach.
o In many cases, additional field data are needed on
which to base water quality-based controls.
o New techniques are now available for developing needed
toxic controls and improving controls for conventional
pollutants. EPA must work with State pollution control
agencies to ensure that they are sufficiently staffed,
equipped, and trained to use these new techniques.
These techniques include methods for setting site-specific
water quality standards, as well as biomonitoring,
hydrological, and modeling methods for screening
discharges and developing WLAs/TMDLs. New biomonitoring
techniques, for example, allow sensitive measurements
of in-stream chronic toxicity.
The Agency and the States must ensure that data are available
to fully meet this objective. If data are not available, additional
monitoring may need to be conducted. However, States generally
do not have enough resources to increase their monitoring efforts,
especially for toxic pollutants (See Table 1 below).
Table 1: Shortfall in Wasteload Allocations and Intensive Surveys
Conventional
Pollutants
Toxic
Pollutants
WLAs/Year
Existing Needed
800 1100
80 800
Intensive Surveys/Year
Existing Needed
350 450
40 350
Source: Estimates based on data contained in: Regional Wasteload
Allocation Survey, January 1983. GKY and Associates, Inc.
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Extent to which Needs Are Being Met:
EPA has issued a Policy for the Development of Water
Quality-Based Permit Limitations for Toxic Pollutants, This policy
provides for a strong program in developing water quality-
based controls. OW and ORD are working to develop interim and
long term technical guidance in support of this policy. The
interim guidance, the Technical Support Document for Water
Quality-Based Toxics Control, will include state-of-the-art
information on developing wasteload allocations for both specific
pollutants and whole effluent toxicity. Guidance is also being
prepared on currently available biomonitoring techniques for
characterizing effluent toxicity and assessing instream impacts
on designated uses. In particular, OW is working with the EPA
Corvallis laboratory, academicians, and selected States to compile
a handbook on bioscreening methods. OW is providing guidance on
developing wasteload allocations for conventional pollutants.
OW is also supporting the development of methods for measuring
chronic toxicity of both effluent and instream samples and the
use of these methods in the field for developing WLAs based on
toxicity.
Other policies that have been developed to support the
implementation of water quality-based controls include the
Advanced Treatment Project Policy; the revised Municipal Compliance
Policy; and Regulations on the Redefinition of Secondary Treatment
and on BOD/CBOD Tests.
OW also trains the Regions and States on wasteload allocation
methods, water quality modeling, monitoring, and related topics.
In addition, the Center for Environmental Modeling (CEM) in
Athens, GA and the Center for Environmental Research Information
(CERI) in Cincinnati, OH provide seminars on the use of specific
water quality models supported by CEM. The Environmental Research
Laboratory at Duluth, MN provides training seminars on toxicity
testing to the Regions and provides on-site training to State
personnel during monitoring studies.
Objective II - Conduct Sound Assessments
The Congress, the Administrator, and EPA program managers
need to know the status of the nation's waters so that they can
make decisions concerning program priorities and regularly provide
reports to the public on the state of the environment, important
trends over time, and Agency accomplishments. National and
Regional assessments of water quality provide this type of critical
information.
The Basic Water Monitoring Program (BWMP) was developed in
1977 to provide a framework for responding to these sorts of
program needs. This program is still in effect. It calls for
EPA and the States to operate a national network of fixed monitoring
stations; to develop a pilot biological monitoring program; and to
report on water quality under Section 305(b) of the Clean Water Act.
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Although significant gains have been made in conducting
reliable national and regional assessments as a result of the
BWMP and since its implementation, data gaps and monitoring
inconsistencies still remain. For example:
o A review of the BWMP has found that the fixed station
network has little statistical reliability for national
assessments, and that more emphasis is needed on biological
monitoring. We therefore need to update the program.
o While the BWMP substantially reduced fragmentation
within the monitoring program, some fragmentation still
exists.
o More attention must be focused on lakes, estuaries, and
coastal waters.
o We need to learn more about the geographic extent, full
impact, and sources of toxic pollution.
o We need to evaluate water quality conditions and trends in
areas currently not known to have problems.
o We need to conduct special studies to answer questions
requiring management attention. (For example, are persistent
toxics accumulating in the food chain, and if so, where?)
o We need to know about the full nature and extent of nonpoint
source impacts on water quality and the relative success of
different approaches to control nonpoint sources.
o We need to conduct analyses on the extent to which waters
support recreational (especially "swimmable") uses.
o We need to improve the quality assurance program.
Extent to Which Needs are Being Met:
Since the implementation of the BWMP, EPA and the States
have been working to correct the limitations in the assessment
process. First, in 1981-83, EPA designed and implemented an
approach for computing statistically reliable estimates of national
water quality conditions using a probability sample of waters and
biological data. The first successful application of this approach
is the recently completed National Fisheries Survey. Second, EPA
and the States developed specific, consistent measures of water
quality status and progress under the EPA-sponsored "States'
Evaluation of Progress Under the Clean Water Act" (STEP) project.
These measures have been tested and adopted as part of the baseline
of information States should provide within the Section 305(b)
reporting process. Third, major environmental concerns have
been identified at the Regional level through the pilot 1983
National Environmental Management Reports.
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Objective III - Evaluate Control Programs
The Congress, the Administrator, and EPA program managers
must evaluate program effectiveness. They need to know the
effectiveness of the programs designed to protect water quality
so that they can review past actions and formulate necessary new
actions. Examples of the questions that must be answered and
the decisions that must be made based on these answers are as
follows:
Question: From the national perspective, how effective are existing
permits in controlling water pollution from point source
dischargers?
Decision: Adjusting the Agency's control program, as necessary.
Question: How effective are existing pretreatment controls?
Decision: Changing existing pretreatment controls, where needed.
Question: How effective are existing nonpoint source controls?
Decision: Adjusting the Agency's control program, where necessary.
Data Needs:
o We need direct information on how well Clean Water Act
pollution control programs are working. Because of
limited resources, States generally concentrate their
efforts on setting controls in areas such as priority
waterbodies, and not on assessing the effects of these
controls. As a result, managers must rely on theoretical
information such as a projected loading reductions in
order to assess the effectiveness of control activities.
For example, Agency attempts to develop "before-and-after"
studies on Advanced Wastewater Treatment (AWT) projects
have been frustated due to lack of post-construction
monitoring data.
o We need national studies to determine whether problems
detected at the local level are found in similar areas
nationwide.
o In many cases, data which could be used for program
evaluations are neither reported to EPA nor properly
integrated with other data. EPA and the States must
make these data available so the EPA can more effect-
ively evaluate control programs.
Extent to Which Needs are Being Met:
Improved methods of assessing national water quality
conditions, such as the National Fisheries Survey approach and
the consistent measures adopted for the Section 305(b) process,
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will help the Agency meet its program evaluation needs.
We have made progress in developing "modeled" success
stories of Best Practicable Treatment (BPT) with the development
of the River Reach File (RRF), the RRF routing and graphical
display system, the industrial facilities discharge file
(IFD)/Reach File interactive system, and the theoretical
assessments we make from them, e.g., RIAs for effluent guidelines.
PROGRAM SUPPORT FUNCTIONS
In addition to the three basic objectives of the monitoring
strategy, three program support functions common to these objectives
must also be addressed. These are: improving EPA oversight of the
States; improving data quality by effectively implementing the
Agency's mandatory Quality Assurance/Quality Control (QA/QC)
Program; and managing data systems so that data are more useful
to program managers. These support functions are addressed
briefly below, and in more detail in Sections 3, 4, and 6.
Improving EPA Oversight of the States;
EPA requires the following data from the States: appropriate
assessment data; appropriate screening data; and all regulatory
monitoring data including data needed for approvals of water
quality standards and wasteload allocations and/or total maximum
daily loads.
At this time, the most commonly reported information is
Section 305(b) assessment data. EPA must receive additional
data generated by the States through the regulatory monitoring
process and data collected after controls are in place.
Improving Data Quality;
Wide disparities still exist in the control and reporting
of data quality at the State level. Confidence in the data is
in question, particularly for use in national assessments.
STORET data, for example, currently contain no description of
data quality.
The new emphasis on biomonitoring and toxics has increased
the need for audits of water quality laboratories. A guidance
document has been developed by OW and ORD for the preparation of
QA project plans which help ensure the quality and utility of
Agency, State, and contractor monitoring data. Application of
this guidance document has proven highly successful in a wide
number of Agency and State programs including water programs,
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Resource Conservation and Recovery Act (RCRA) programs, and
Superfund. However, State users have requested expanded technical
guidance in establishing data quality objectives, monitoring
network specification, field guidance, and data management.
Such expanded guidance will greatly facilitate plan preparation,
ensure data quality, and improve comparability of data.
Managing Data Systems;
As discussed in the Final Report of the Long Range ADP
User Requirements Task Force entitled "Assessing EPA's Long
Range Information System Needs" (EPA, 1983), there is a
fundamental need for linking logically related data bases. In
the water quality program, EPA and State environmental managers
need a system to assess current water quality and trends, track
wastewater treatment plant construction progress, track grants
issued for designated wastewater treatment plants, and review
permit and discharge data.
At present, EPA and State managers must access different
data systems for ambient data, source data, and construction
grants data. These systems are essentially independent and
thus require independent retrievals. In addition, these data
systems generally work only in the "batch" mode and generally
do not provide for interactive analysis of the data. One
positive development in linking these data bases has been the
development of the River Reach File (RRF) and the IFD/River
Reach File interactive system, both of which allow for ambient
data, source data, and construction grants data to be tied to a
common segment or river reach. The RRF must now bridge the
gap between data bases. Without this linkage, program managers
will continue to find it difficult to make regulatory decisions
and assessments using these different types of data.
Another positive development is the formation of the Program
Systems Task Force of the Office of Information and Resources
Management. This Task Force will work with the Program Offices
to prevent duplication and to integrate logically related data
bases.
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SECTION 2
WHAT TECHNICAL BARRIERS AND OPPORTUNITIES AFFECT OUR ABILITY
TO MEET NEEDS?
Research needs and quality assurance problems are technical
barriers to the monitoring program. However, in many areas we
are making significant progress in dealing with these issues and
opening up new opportunities. This section discusses the technical
barriers, as well as the opportunities, that affect our ability to
meet water quality monitoring program needs.
Technical Barriers
Research needs:
Listed below in briet capsule form are some of the Agency's
most critical research needs; a more comprehensive list is
generated within the OW/ORD water quality research committees and
will be expressed in detail in the OW/ORD Crosswalk which will be
appended to this document later this year.
More attention has been focused on toxic pollutants in the
past five years with the development of new monitoring and
analytical techniques. However, many research needs remain to be
met. The Office of Water needs:
o Better data on the relationship between synthetic
chemicals and biological conditions.
o Analytical techniques suitable for detecting low level
ambient concentrations of additional toxicants. Many of
the analytical detection limits for toxics are above
the ambient water quality criteria.
o Information on the additivity/persistence of chronic
toxicity.
o Health bioassays suitable for developing permit limits.
o To develop an ability to reassess historical samples or
data for pollutants of current interest. A specimen
banking program or a computer library of GC/MS Tape
Scans would provide this capability.
o To develop toxic criteria for fish and sediments.
In addition to these needs for the study of toxic pollutants,
needs exist in other areas of research. For example, OW needs:
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o Synoptic data sets which can be used to calibrate and
verify receiving water models, especially under critical
(design) conditions.
o Biological data that can be used to identify site-specific
critical conditions other than summer time high temper-
ature/low flow conditions. Examples of this type of
data include information on conditions such as algal
bloom death decay, ice cover, egg hatching, etc.
Technical quality assurance (QA) problems:
Some technical QA issues include the need for data quality
acceptance criteria including the ability to measure and designate
data quality for intended uses; adequate field and management QA
audit protocols; coordination in identifying applicable field
monitoring protocols; uniform statistical methods and standard
methods for biomonitoring, bioassay, and health effects testing;
continued support for ORD reference standards and audit sample
program; the need to identify specifically what QA/QC in-
formation should be stored with water quality data; and the
issuance of 40 CFR 136 as amended (the "Guidelines Establishing
Test Procedures for the Analysis of Pollutants").
Opportunities
As mentioned in the overview to this strategy, many techno-
logical developments are now available for use in the water quality
monitoring program.
In the area of toxic pollutants, the development of sensitive
analytical techniques over the past 5 years is now allowing the
detection of some toxic substances at physiologically active
concentrations. In addition, the development of new bioassay and
biomonitoring techniques has allowed us to better assess the
hazard from complex effluents and to detect low levels of toxicity
in receiving waters.
The increasing use of Automated Data Processing (ADP)
equipment and software is rapidly changing the nature of many
monitoring activities. As discussed in the recent final report
of the Long Range ADP User Requirements Task Force (EPA, 1983),
new technology is making possible the automation of such tasks
as project tracking, workload planning, and data reduction and
analysis. User-friendly ADP "tools" are being widely applied
throughout the monitoring program. As will be discussed in
Section 6, OW has developed two systems that are setting the
stage for the routine application of high technology automation
for data reduction and analysis. These are the River Reach File
(RRF) Routing and Graphical Display System, which "routes" pollu-
tant concentrations as they move downstream from sources and
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uses high technology graphics to display hydrographic information;
and the Industrial Facilities Discharge (IFD) File/RRF interactive
system, which links water quality, waste treatment facility, and
other data through the use of stream reach numbers. These are
currently being pilot tested.
OW is evaluating other technologies to define their role in
the water monitoring program. Some of these technologies may be
introduced into the program on a pilot basis. These include the
use of remote sensing technology as a monitoring reconnaissance
tool; aerial photography to locate and track discharge plumes;
remote sensing imagery to assess land use changes to determine
how these changes affect water quality; subcellular biological
indicators such as metallothionein and glutathione to assess the
full impact of environmental stress on biological organisms; the
study of fish age and growth as indicators of water quality
change; rapid toxicity methods as screens in identifying the
presence or absence of toxicity (e.g., the MICROTOX device);
and highly developed computer systems and associated analytical
packages for water quality analyses.
Other technologies are in need of further research. These
include the use of automatic monitors that can analyze metals and
organics and telecommunicate the results of those analyses; the
use of genotoxicological methods to measure potential human health
impacts; the use of laser-based optical systems for analyzing
phytoplankton communities as indicators of water quality; and
the rapid detection of acute concentrations of toxic substances
in surface waters using fish behavioral phenomena. In order to
help meet these needs, OW and ORD are updating a crosswalk that
was developed in FY83 between OW program needs and ORD research
activities. This crosswalk gives Agency decisionmakers the
opportunity to determine the impact of individual research acti-
vities on the overall monitoring program, and to improve coordi-
nation between the two (see Section 7 for implementation
schedule.)
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SECTION 3
WHAT IS THE MONITORING PLAN TO MEET NEEDS?
This section addresses the monitoring program plan that EPA
and the States will follow in meeting the needs expressed in
Section 1, taking into account the constraints and the opportuni-
ties expressed in Section 2. The monitoring program is discussed
in terms of the three monitoring objectives stated earlier in
this strategy.
OBJECTIVES
For each objective, activities which are expected to be
achievable with current resources are listed first, followed
by those which would require additional resources. Additional
information on those activities requiring additional resources
is contained in Appendix A, which is available upon request.
Objective I - Advance the Regulatory Monitoring Program
Assuming Existing Levels of Program Resources:
o The new water quality monitoring policy included in this
strategy addresses a number of the needs in the regulatory
monitoring area, including the identification of waters
most needing water quality-based controls, i.e., priority
waterbodies; the development of needed controls for toxics
and conventional pollutants; and the use of data collection
requirements in permits.
In implementing this policy, EPA expects that each State
will set up a systematic approach for identifying polluted
waters and for selecting priority waterbodies. The Agency
defines priority waterbodies as those areas for which
pollution abatement and control decisions are most needed to
prevent or reverse the impairment of a designated use.
(See Figure 2.)
Figure 2: Priority Waterbodies
WATERS
MEETING • PRIORITY
I
DESIGNATED | WATERBODIES
USES
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WATERS NOT
MEETING
DESIGNATED
USES
-------
Results of the State analyses, including a list of priority
waterbodies and of the types of actions planned for each,
are to be reported to EPA in Section 305(b) reports and/or
Section 205(j) updates. States may also continue to include
these lists in annual work plans or water quality management
plans if they wish. It is recognized that the list of
priority waterbodies will change as more information becomes
available on toxics and the effects of Best Available Treat-
ment (BAT) and other technology based controls.
o In £"¥84, the Office of Water (OW) and selected Regions and
States are preparing the Technical Support Document for
Water Quality-Based Toxics Control. This document
supports the Policy for the Development of Water Quality-
Based Permit Limitations for Toxic Pollutants, a recent
EPA policy initiative involving the application of biological
and chemical assessment techniques to control toxic pollu-
tion. The Technical Support Document provides interim
technical guidance for assessing and regulating the dis-
charge of toxic substances to the waters of the United
States. In addition, it recommends approaches to problems
which tend to be complex and site-specific. OW is also
developing guidance on developing wasteload allocations
for conventional pollutants and guidance for assessing
in-stream biological impacts. The policy and these guidance
documents form the monitoring plan in the regulatory
area. OW will conduct workshops using the Technical
Support Document as a training manual.
The Office of Water will also work with selected Regions
and States on activities in prototype Wasteload Allocation
(WLA) field studies, preparing training materials and
written guidance on the design and analysis of these
studies. OW will prepare general guidance on conducting
appropriate field surveys in streams and rivers for WLA
development.
o In FY85, field work will be expanded to involve selected
States in prototype standards-to-permits exercises where
specific permits will be reviewed, field studies designed
and conducted, WLAs developed, and permits revised, where
needed. Methods for estuarine biomonitoring will be eval-
uated and prototype field studies conducted. OW will
develop general guidance on conducting such studies to
complement FY84 guidance on rivers and streams.
OW will also establish, to the extent practicable, a set
of training programs including training on developing
toxic limits using both the pollutant-specific and biomon-
itoring techniques, and detailed seminars on particular
technical aspects of the process of developing water
quality-based controls.
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Assuming Some Additional Resources:
o Once BAT is in place, implementation of site-specific
water quality-based controls will require a considerable
increase in field data collection activities (particularly
for biological assessments involving effluent toxicity
testing and instream impact assessment) and water quality
analyses. Few Regions and States currently possess
sufficient resources or skilled personnel to routinely
conduct the basic studies which will be needed to develop
appropriate toxics controls.
Furthermore, demand from the States for technical assistance
in large scale investigations will increase substantially,
particularly for toxicity testing and water quality
analysis. Therefore, EPA will establish a task force of
Regional, Headquarters, and State personnel to evaluate
the magnitude of the resource shortfall and the available
options for acquiring any new needed resources. In the
interim, a "down payment" is recommended (see Appendix
A for more details).
o A limitation of the regulatory monitoring program is the
current backlog of samples at the State level which require
toxics (especially organics) analysis. In response to
this concern, OW has prepared an initiative to give EPA
regions the ability to contract for toxics analyses for
their States (see Appendix A for more details).
Objective II - Conduct Sound Assessments
Assuming Existing Levels of Resources:
o The Basic Water Monitoring Program will be revised to
include the following systematic monitoring approach for
the preparation of sound National and Regional assessments.
This approach meets the requirements of section 104(a)(5)
of the Clean Water Act.
National and Regional assessments will be conducted using:
(1) a focused monitoring for trend analysis of waters not
meeting designated uses; (2) water quality information
provided through established reports such as Section
305(b), 205(j)f and environmental management reports; and
(3) periodic national surveys focusing on specific
questions that cannot easily be answered through Section
305(b) and EMRs. Each of the components is discussed
below.
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1. Focus on Waters Not Meeting Designated Uses:
This activity will be discussed in more detail in the
revised Basic Water Monitoring Program. It consists
of the following steps:
The Office of Water, the Regions, and the States will
compile a list of waters not meeting designated uses.
These are not necessarily priority waterbodies (see
definition of priority waterbodies given under
Objective 1).
This list will be maintained as a computer file at
Headquarters and will be accessible to the Regions
and States. For consistency, these waters will be
coded by river reach file number to the extent possible.
The States will be responsible for developing monitor-
ing plans for waters not meeting their designated
uses. Monitoring plans will be developed following
EPA guidance (to be provided in the revised BWMP)
which will outline the types of questions that are to
be answered for each site. The actual conduct of
monitoring activities will be negotiated between the
Regions and the States. At a minimum, these plans
should describe the type of monitoring to be performed,
QA/QC considerations, and data handling and storage.
They should also describe a balanced monitoring approach
using appropriate measures that will best describe
pollutant loadings, physical changes, and impairments
to the aquatic community. The Regions will approve
these plans; the Office of Water will review a sample
to ensure an appropriate level of national consistency.
Every attempt will be made to ensure that information
collected for these waters, including historical
data, is stored in STORET to allow for data integration
and analysis at both the Regional and National levels.
2. Established Water Quality Reports:
In 1984, and biennially thereafter as required by the
Clean Water Act, the States will prepare Section 305(b)
reports. EPA will compile this information and summarize
it in a report to the Congress and the public. Head-
quarters will continue to provide guidance to the
States for preparing the reports, building upon the
baseline established in FY84 which incorporated the
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recommendations of the EPA/ASIWPCA STEP project. The
Regions will be responsible for reviewing the reports,
evaluating their quality, and forwarding them to Head-
quarters .
On a six-year cycle starting with their 1988 submission,
the States will submit long-term trend information as
part of their Section 305(b) reports. These long-term
studies were recommended as a result of the STEP project.
In an effort to further improve the effectiveness of
the Section 305(b) reporting process, the Office of
Water and the Regions will provide more feedback to
the States on the quality of their Section 305(b)
submissions.
The Regions will perform assessments as needed for
Environmental Management Reports (EMRs) and submit
these reports every two years. The next drafts are
due in September 1985, with final reports due in
January 1986. In alternate years, the Regions will
submit interim documents which update the EMRs.
These reports complement the 305(b) reports without
duplicating them, and offer the Regions an opportunity
to: 1) evaluate State environmental progress; 2)
evaluate multi-media issues; and, 3) discover, develop
and communicate Regional priorities to Headquarters
and States.
One limitation of the assessment program is that many
States cannot monitor all their waters because of
limited resources. Generally these unmonitored
waters are those where designated uses are thought
to be met; they may, however, constitute a large percen-
tage of the States' total waters. In FY84, MDSD will
prepare guidance on techniques by which the States and
Regions can assess these waters using bioscreening
techniques. A handbook will be produced which can be
used in the field to assess unmonitored waters and to
determine, using a minimum of resources, whether or
not they are affected by significant water quality problems
(Problems are defined as impairments of the designated
uses established in the State Water Quality Standards.)
In FY85, HQ will work with the Regions and States to test
this handbook in the field. Revisions to the handbook
will be made based on these field applications.
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Periodic National Surveys:
On a six-year cycle beginning in 1988, the Office of
Water will complete national assessments of the Nation's
waters using a statistical approach. This work will
complement the State Section 305(b) assessments, the
Regional environmental management reports, and the
Section 305(b) long-term studies. Each assessment
will follow a design similar to the National Fisheries
Survey, but will be fine-tuned as needed to meet
additional needs that may exist at the time it is
developed. The design of these surveys will include
a stratum of waters not fully supporting designated
uses. In this way, estimates can be made for these
waters in comparison to the Nation's waters as a
whole. The next study design will be completed in
FY86 and the study initiated in FY87. These national
studies are needed because, unlike EMRs and Section
305(b) reports, they can be designed to answer specific
questions of short-term interest to program managers.
They also compensate for the inevitable National var-
iability that exists in the Section 305(b) and EMR
processes, and therefore are a more effective way of
producing statistically reliable national level estimates
of specific water quality conditions. Further, because
they are statistically designed they allow for special-
ized statistical testing, e.g., testing for significance.
They also provide a more direct vehicle for gathering
water quality information from other federal agencies.
The experience gained in the development of the National
Dioxin Strategy and from projects that address the
problem of other high visibility chemicals has indicated
the need to anticipate potential risks from different
persistent and bioaccumulative pollutants. EPA needs
to identify those pollutants which may present a human
health or environmental threat and, before they become
major media issues, develop information on their
presence in the environment and on associated risks.
During FY85, as the dioxin study nears completion, OW
will develop a work plan for using the investigative
approach developed for the study to evaluate other
pollutants of concern. Because one focus of this
effort is on bioaccumulative pollutants in fish, OW
is discussing the effort with the U.S. Fish and Wildlife
Service.
The Office of Water, working with ASIWPCA, the Regions,
and the States, will continue to focus attention on
nonpoint source water quality impacts and controls.
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In this regard we will: review those priority waterbodies
that the States have identified as being affected by
nonpoint sources; analyze existing data to assess the
full nature and extent of nonpoint source impacts;
and fill data gaps where necessary. Sets of baseline
data will be sought out for before-and-after analysis.
EPA will use the data base established at Ohio's
Heidelberg College as a pilot project. Also, working
with the States through ASIWPCA, EPA will establish
data collection and analysis procedures for nonpoint
source pollution.
The Office of Water and the Regions are currently
involved in the National Surface Water Survey, which
is part of a larger Agency effort to evaluate the
effects of atmospheric depositions. In FY84 and
PY85, the Regions are expected to expend resources in
the field to support this study.
The Office of Water is now
management team so that OW
reflected in the effort.
represented on the study's
needs and concerns are
Assuming Some Additional Resources:
Priority A - To ensure the continued successful development
of the Section 305(b) reporting process,
the Regions will provide more technical
assistance to the States.
Priority A - EPA, working with the States, will conduct
a study to evaluate water quality in terms
of "swimmable" use.
Priority A - OW, with Regional review, will further develop
the Bioaccumulative Pollutant Study by
evaluating available information from a
number of sources, including data from the
effluent guidelines program, the pesticides
program, the Basic Water Monitoring Program,
and the toxics program to identify candidates
for further investigation. Factors to be
evaluated include toxicity, persistence,
production levels, releases to the environment,
measured levels in the environment, and
bioaccumulative potential.
Priority A - OW, working with the States, will conduct a
National study to identify sites where in-
place toxicants (toxicants in sediments) are
presenting potential environmental risk.
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Priority A - As a follow-up to the Bioscreening Handbook,
OW will evaluate the most promising biological
indicators for use as standardized procedures.
This will be done in part through pilot
tests with selected States.
Priority B - EPA, with the cooperation of the States and
other federal agencies, will design and
conduct a national level study of the Nation's
waters to further define the full nature and
extent of water quality impacts due to
nonpoint sources and, most importantly, to
evaluate the relative success of different
control approaches.
This special study will assess nonpoint source
impacts on designated uses. The primary
focus of the study will be on agricultural
contributions. It will be conducted to
further investigate the results of the National
Fisheries Survey, the 1982 State Section 305(b)
report analysis, and the 1983 Environmental
Management Report Analysis, all of which
cite water quality problems directly attri-
butable to agricultural pollution. Headquarters
will be responsible for designing this study.
The study design should be completed and
the study initiated in FY85.
Priority B - OW will conduct an assessment of the nation's
lakes. We will review the data generated
by the Clean Lakes Program and the National
Surface Water Survey to determine whether
OW needs are satisfied (for example, are
toxics assessed?) and if necessary take
steps to ensure that these needs are met.
Priority B - OW, in cooperation with the National Oceanic
and Atmospheric Administration (NOAA), will
conduct an assessment of the Nation's
coastal waters. Working with the Regions, OW
will first assess available data on coastal
water quality and then develop a national
study if necessary. This study will be
done in cooperation with NOAA. Again,
the emphasis is on toxic contamination.
Priority B - OW will establish a large national contract
for use by the Regions in meeting assessment
needs which include, but are not limited
to, the following:
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- Providing additional support to implement
the monitoring system mentioned above to
ensure that all waters not meeting designated
uses are routinely monitored.
- In cooperation with the States, ensuring that
waters meeting designated uses are monitored
in order to identify actual or potential
problems.
This contract need not necessarily differ
from the one mentioned above under the
objective to Advance Regulatory Monitoring.
Priority B - Working with the States, Regions and other
federal agencies, EPA will establish a procedure
for evaluating historical water quality
information. Examples of suggested activities
include the establishment of a GC/MS tape
library and a specimen banking program.
Objective III - Evaluate Control Programs
Assuming Existing Levels of Program Resources:
o OW will rely upon the general overview of the States'
water pollution control program as contained in the Section
305(b) reports (especially segment level discussions which
will help identify areas needing water quality-based
controls) and other specific data reports requested by the
Regions. This will provide program managers with at
least a general base level of information on the effective-
ness of water pollution control programs, but will not
provide sufficient information to assess the effectiveness
of individual components of the program.
o OW will continue the existing modeled analyses on the
water quality effects of BAT.
Assuming Some Additional Resources:
Priority A - The Office of Water, the Regions and the States
will review assessment data and other data pro-
vided by the States for a pattern of pollutant
problems downstream from certain sources.
If patterns emerge, Headquarters will initiate
a study of these sources and make appropriate
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recommendations concerning the need for
further national guidelines development.
This may involve previously regulated or
"new" pollutants. Because many of these
studies will be regional rather than national
in scope, particular Regions may be selected
to work with Headquarters personnel in designing
the studies.
Priority B - Headquarters will alert Regions and States to
potential "problem" industries or pollutants
based on effluent monitoring, GC/MS tape
scans, or effluent toxicity test results.
Statistically designed sampling plans may be
needed.
PROGRAM SUPPORT FUNCTIONS
In terms of the three program support functions (improving
EPA oversight of the States; improving data quality; and
managing data systems) OW will conduct the following activities
addressing the needs expressed in Section 1 of this strategy:
Improving EPA Oversight of the States
Assuming Existing Levels of Program Resources:
o The Regions and the States will implement the policy ex-
pressed in this document. This includes negotiating with
the States to obtain appropriate screening and assessment
data needed by the Regions to effectively operate the
water quality program.
Assuming Some Additional Resources:
OW will make available, to the
national contract mentioned in
ing and assessment sections of
facilitate the storage and use
water quality information.
Regions and States, the
both the regulatory monitor-
this strategy. This will
of currently inaccessible
Improving Data Quality
Assuming Existing Levels of Program Resources:
o Efforts in FY84 will concentrate on developing initial
implementation of the Agency's new QA requirements. The
OW Work/Project Plan guidance will be expanded to further
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expedite plan preparation and improve data quality. Program
office and Regional pilot tasks will be undertaken to
develop data quality guidance, establish QA audit procedures,
and assist States in planning for and controlling data
quality. In FY85, work will proceed further on pilot
implementation of the improved guidance and audit systems.
QA performance reviews will be undertaken with program
office, Regional, and State participation.
During FY86, the Regions and ORD Cincinnati will implement
improved audits of water quality laboratories, with Regions
visiting each State laboratory at least once and ORD visiting
each Regional laboratory at least once. During FY86,
deficiencies that were noted during the FY85 audits and
performance reviews will provide the basis for improved
QA guidance and controls. Workshops will be designed and
conducted through Regions for States to help ensure uniform
data quality controls for improved confidence in, and
comparability of data for, local and national assessments.
Data quality indicators will be developed to "tag" or
connect data quality to specific data sets and facilitate
data use from management systems such as STORET.
Managing Data Systems
See Section 6 of this strategy for a discussion of this area.
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SECTION 4
HOW WILL WE IMPROVE OUR MONITORING DESIGN?
This section addresses Office of Water (OW) activities
aimed at improving the design of monitoring activities. More
attention will be given to this issue in the forthcoming revision
to the Basic Water Monitoring Program (BWMP).
The term "monitoring design" encompasses not only the planning
of monitoring activites to be performed at a given site, but also
QA/QC requirements for the activities, storage of the resultant
data, and, most importantly, interpretation of the data in order
to meet those program needs that originally prompted the monitoring
activities.
The establishment of an efficient and adequate monitoring
program requires that those responsible for monitoring maintain
frequent and substantive contact with those programs needing
information. As the distance increases between the field monitoring
personnel and the program offices requesting the information, it
becomes more and more difficult to ensure proper monitoring
design. Therefore, in addition to stressing methods of obtaining
data of consistent, high quality, OW is seeking to improve methods
of communicating program needs to monitoring personnel.
OW is engaged in the following activities aimed at better
communicating monitoring program needs to the Regions and States,
and ensuring consistency in the results of monitoring efforts:
o Developing better program guidance to define program
needs. This involves preparing documents such as the Office
of Water Operating Guidance and Accountability System;
the guidance for the preparation of State Section 305(b)
reports; and the guidance for the preparation of Environ-
mental Management Reports (EMRs). Included in this
activity are efforts to better coordinate issued guidance;
OW is working to reduce the duplication of effort that
occurs when different program offices request the same
information from the Regions and States. One such effort
has been coordination of the EMR, Section 305(b), and
STEP projects.
o Developing workload models with the Regions. Workload
models involve careful evaluation of available resources
to ensure that needs can be met; unaddressed needs are
then analyzed and, where appropriate, translated into
budget initiatives.
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o Developing better technical guidance and training methods.
OW and ORD are working hard to provide specific guidance
and training to the States and Regions on various components
of the monitoring program. These technical guidance
documents and training seminars identify the appropriate
analytical tools for given monitoring situations and conse-
quently define the appropriate monitoring design.
o Developing better data analysis and interpretation
procedures. OW, working with the newly established Program
Systems Division of the Office of Information Resources
Management, is working to make available analytical
procedures (such as SAS, the Statistical Analysis System)
that will facilitate data analysis. OW is also providing
guidance on trend analyses and will be providing guidance
on a variety of analytical models that have been used
successfully by several Regions and States to interpret
data.
o Developing better guidance on the use of statistically
based monitoring for water quality assessments. OW has
supported the efforts of the Office of Policy, Planning,
and Evaluation to develop a document on the design of
statistical surveys (Survey Management Handbook: Guidelines
for Planning and Managing a Statistical Survey) . OW
also plans to publicize the statistical design used in
the National Fisheries Survey.
o Developing better QA/QC guidance and field and laboratory
methods. OW is actively involved with ORD, through the
Consolidated Water Research Committee, in efforts to
ensure that, in areas of common interest, OW program needs
are addressed in ORD activities. The list of specific
ongoing or planned ORD activities that meet OW program
needs is too extensive to be included nere; the OW-ORD
crosswalk, which was discussed in Section 2, will provide
more detail on these activities.
As mentioned at the beginning of this section, specific
monitoring design considerations for the various elements of this
strategy will be discussed in the revised BWMP. Work will begin
immediately on revising the BWMP and will be closely coordinated
with the Regions and States through technical and policy committees.
The format of: the revised BWMP will be essentially the same as it
was in the original 1977 report. The revised report will be
completed by October 1984.
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SECTION 5
HOW WILL WE WORK WITH OTHER PROGRAMS AND FEDERAL AGENCIES?
This section addresses the issue of needed coordination in
water monitoring activities both within and outside the Agency,
and our plans to improve that coordination.
Intra-program and Inter-program Coordination:
Many program offices within EPA become involved in studies
which include, at least in part, water monitoring activities. In
many cases, these activities are initiated without proper
coordination between responsible offices. This often leads to
duplication of effort, "reinvention of the wheel," and lost
opportunities to improve the activity by consolidating expertise
and resources.
One goal of the Environmental Monitoring Policy is to ensure
effective and coordinated Agency-wide processes for planning and
conducting monitoring activities. In meeting this goal, the
Office of Water will, first, meet with those EPA program offices
engaged in water monitoring activities and, through their respective
monitoring strategies, crosswalk activities between programs. If
appropriate, long range plans will be formulated to coordinate
activities. The Office of Water (OW) has already met briefly
with the Office of Pesticide Programs and the Office of Toxic
Substances to discuss areas of coordination. OW also meets
regularly with ORD as a member of the National Surface Water
Survey management team and through the Consolidated Water Research
Committee. Second, OW and all other Agency offices that share
responsibilty for water monitoring will review all major water
monitoring activities planned or ongoing within the Agency to
ensure that these activities are appropriately coordinated.
Reviews will be conducted as part of the Agency's Peer Review
process.
Coordination Among Federal Agencies:
The purpose of coordination among federal agencies is to
meet mutual needs with a minimum expenditure of resources. Trad-
itionally, EPA and States have cooperated with the U.S. Geological
Survey (USGS) at the field level to collect and analyze samples
as part of State fixed station networks. In addition, EPA
actively meets with USGS at the Headquarters level on a quarterly
basis to discuss issues of common concern. These cooperative
efforts should continue. OW has also cooperated with the U.S.
Fish and Wildlife Service on national assessments and expects to
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cooperate further in the study of bioaccumulative pollutants in
fish. Many State EPA organizations rely upon local State fish
and game organizations for biological data. This should continue.
In the nonpoint source area, OW works with the Department of
Agriculture, the Soil Conservation Service, the Bureau of Land
Management, and the National Forest Service. In the study of
oceans, OW coordinates its efforts with the National Oceanic and
Atmospheric Administration (NOAA). In the future, OW expects to
cooperate further with NOAA and its National Marine Fisheries
Service (NMFS) in studies of shellfish in coastal areas.
In summary, considerable cooperation exists among federal
agencies and this should continue. However, duplication of effort
and complications in both the QA/QC area and data base compatibility
are still potential problems. To keep these problems at a minimum,
OW will step up communication with other federal agencies as a
routine part of the ongoing monitoring program effort and will
encourage States to do the same. Further, OW will continue to
work with the USGS Office of Water Data Coordination and other
related offices to help integrate data for Federal, State, and
local use.
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SECTION 6
HOW WILL WE MANAGE DATA SYSTEMS?
Data management is here defined as the linking of logically
related data bases and the development of interactive retrieval
programs. This allows users to interactively retrieve, from
these linked systems, information that is relevant to their
particular analytical needs. It in no way involves the develop-
ment of a new data system.
At present, EPA and State managers must access different
data systems for ambient data, source data, construction grants
data, and other data necessary to support program decisions. For
example, water quality data are stored in the Permit Compliance
System (PCS), and information compiled from industrial and municipal
facilities discharge monitoring reports is stored in STORET's
Industrial Facilities Discharge File (IFD). Flow, fish kills,
regulatory impact assessments, and bioassay data occupy separate
files .
This data management problem is exacerbated by the fact
that several large sources of information, e.g. data produced
for the Superfund Program by national contract laboratories, are
not currently stored in systems that are available to data users.
In addition, several State and EPA regions maintain manual files
of biological information that have not been stored in computer
systems.
The responsibility for water data management lies with the
Office of Water. Data management will be coordinated with the
newly consolidated Program Systems Division of the Office of
Information Resources Management. Using as a baseline the key
findings of the EPA document entitled "Assessing EPA's Long
Range Information System Needs" (October 1983) and the opinions and
comments expressed by the OW data user community, the Office of
Water will carry out this responsibility by conducting the following
activities:
o Implementing a data subsystem under STORET (BIOSTORET)
to store and retrieve biological data. This will occur
in FY85; positions are being filled now in Headquarters
to support the system.
o In the short term, making the River Reach File (RRF)
available to STORET users as soon as documentation can
be issued, for purposes of information retrieval and for
applying segment numbers to the STORET Water Quality
File. Reach File update procedures will also be made
available. One long term goal is to assign EPA River
Reach File Numbers to all existing stations in STORET
-27-
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and establish a mechanism for assigning RRF numbers to
all new stations.
o In the short term, making the River Reach File Routing
and Graphical Display System (RGDS) available on a pilot
basis to any interested user. This system uses hydro-
logical information to "route" pollutant concentrations
as they move downstream from sources, and uses high
technology graphics to display hydrographic information.
OW is currenly applying RGDS as part of a pilot effort
with EPA Region 4. The long term goal of this effort is
the full and formal adoption of RGDS into EPA's data
management system.
o In the short term, making the IFD-Reach File interactive
system available on a pilot basis to any interested
user. The long term goal of this effort is the full and
formal adoption of the IFD-Reach File into EPA's data
management system. The IFD-Reach File interactive system
integrates water quality, waste treatment facility,
drinking water facility, stream flow, and criteria and
standards data through the use of stream reach numbers.
o Continuing to support the Construction Grants Evaluation
and Network Tracking System (COGENT), which was developed
to assess the water quality impacts of future wastewater
treatment facilities.
o Continuing to improve basic STORET capabilities. Latest
developments include the establishment of a SAS interface,
the development of a capability to store precision and
accuracy data codes, and the completion of a directory
that will allow users to assign QA/QC information for
groups of data.
With additional resources, OW will: (1) work with other
program offices to fully integrate data bases where feasible.
Special attention will be given to those data collected by the
Superfund/RCRA program; (2) provide contractual support to
computerize data, including relevant QA/QC information, that are
currently not accessible to EPA and State program managers;
(3) fully develop an interactive capability within this integrated
data system to facilitate data retrieval; (4) train the Regions
and States to familiarize program managers with the system's
capabilities; and (5) modify software, where necessary, to improve
the process for adding river reaches to the River Reach File, to
more readily note errors and improve QA/QC procedures, and to
add mileages to the system to further refine site locations.
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SECTION 7
WHAT IS THE SCHEDULE FOR IMPLEMENTING THIS STRATEGY?
This section lists completion dates for the major activities
discussed in this strategy. Specific activities include:
Schedule A - Completing the Monitoring Strategy.
Schedule B - Updating the Basic Water Monitoring Program.
Schedule C - Updating the OW/ORD Crosswalk.
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SCHEDULE A
COMPLETING THE MONITORING STRATEGY
Final strategy transmitted to the
Deputy Administrator
Strategy revised to include OW/ORD
crosswalk
Strategy revised to include updated Basic
Water Monitoring Program
Policy group meeting to review updated
strategy
Final updated strategy transmitted to
the Deputy Administrator
June 15, 1984
October 1984
October 1984
March 1985
May 1985
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SCHEDULE B
UPDATING THE BASIC WATER MONITORING PROGRAM (BWMP)
BWMP reviewed to determine needed
1984 revisions/updating
First draft revision sent to key
members of Policy/Technical Subgroups
for review and comment
Key members of the Policy/Technical
Subgroups meeting to discuss draft
Revised document sent to all Regions
and States for review and comment
Final updated Basic Water Monitoring
Program transmitted to Assistant
Administrator for signature
June 1984
July 1984
August 1984
September 1984
October 1984
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SCHEDULE C
UPDATING OW/ORD CROSSWALK
First draft of OW/ORD crosswalk completed July 1984
1984 Draft reviewed by OW policy committee August 1984
Final crosswalk incorporated into strategy October 1984
Crosswalk updated, if necessary as part of March 1985
full strategy review
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NPD6S COMPUflNCe
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Executive Summary
The Office of Water Enforcement and Permits (OWEP) has the
national program responsibility for monitoring compliance with
and enforcing requirements of both the National Pollutant Discharge
Elimination System (NPDES) and the Pretreatment Program. Agencywide
Monitoring Goals are prescribed by EPA's December 23, 1983 Environ-
mental Monitoring Policy. OWEP has established four Compliance
Monitoring Program Objectives.
This Strategy describes how OWEP plans to meet these goals and
objectives. Table 1 summarizes the current program; Table 2
identifies program deficiencies; Table 3 describes OWEP's plan
to overcome these deficiencies. In Appendix A is an outline of
resources needed to implement the plan.
The plan contains four key elements:
1. Upgrade the Permit Compliance System (PCS), the Agency's
NPDES database to make it more complete and readily accessible.
2. Perform more targeted inspections of permittee facilities to
respond to GAO criticism and Congressional inquiries. EPA
and States will coordinate their inspections through formal
Compliance Inspection Plans (CIP). Certain specialized
inspections will be targeted to specific facilities identified
through OWEP's Discharge Monitoring Report Quality Assurance
Program (DMR OA) and through Quarterly Non-Compliance Reports
(ONCR). In addition to targeted inspections, OWEP will
develop a statistically valid random sampling approach to
inspections to estimate compliance rates for minor facilities
at minimal cost.
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Support E]PA policy on biomoni toring and toxic pollutant permit
1imits. These activities, coupled with an increased number of
specialized inspections, are an important part of the compliance
monitoring program's contribution to the elimination of the
permit backlog and to support permit issuance/reissuance on a
continuing basis.
4. Establish the compliance monitoring and enforcement elements of
the pretreatment program so that the Agency can demonstrate
concrete results from its public commitment to pretreatment.
The program will include guidance, inspections and pretreatment
data management.
Finally, the Strategy deals with the relation of OWEP's com-
pliance monitoring program to other monitoring programs and with
the division of program responsbilities. Technical issues are
also addressed.
- 11 -
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TABLE OF CONTENTS
I. Introduction
II. Current (FY84) Compliance Monitoring Program
Objective 1: Determine/Verify Compliance Status
Objective 2: Reduce Noncompliance
Objective 3: Support permit Reissuance
Objective 4: Monitor Pretreatment Compliance
III. Program Deficiencies
IV. Plan to Meet Needs
A. Compliance Inspection Program Planning Criteria
B. Proposed Activities
Priority 1: Activities Currently Planned but Inadequately
Funded
Priority 2: Activities Needed for Current Needs, but
Unfunded
Priority 3: Activities Needed for Future Needs, But Unfunded
V. Relation to Other Monitoring Programs
VI. Technical Barriers, Issues, and Opportunities
VII. Reponsibility of Headquarters, Regions, States, and Permittees
VIII. Schedule for Implementation
APPENDIX A Resource Needs For Plan
APPENDIX B Objectives of Inspections
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I. INTRODUCTION
The Office of Water Enforcement and Permits (OWEP) Compliance
Monitoring Strategy describes planned OWEP efforts and needs to
meet the following goals of EPA's December 23, 1983 Environmental
Monitoring Strategy:
Goal 1: To collect the right kinds and amounts of data.
Goal 2: To ensure that these data are reliable.
Goal 3: To make these data accessible to decision makers
and other users.
OWEP has the national program responsibility for monitoring and
enforcing National Pollution Discharge Elimination System (NPDES)
requirements and pretreatment requirements under the Clean Water
Act. In addition to the broad Agency goals listed above, OWEP has
established four specific compliance monitoring objectives:
Objective 1: To determine and verify the compliance status
of NPDES permittees.
Objective 2: To bring non-complying facilities into compliance.
Objective 3: To provide technical assistance for permit
reissuance.
Objective 4: To develop and implement an effective Pretreatment
Compliance Monitoring Program.
In this Strategy we describe OWEP's current (FY 1984) compliance
monitoring program, identify its deficiencies and propose solutions.
The major parts of this Strategy relate Agencywide monitoring goals
to OWEP's compliance monitoring program objectives, as shown in
Table 1.
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II. CURRENT (FY 84) COMPLIANCE MONITORING PROGRAM
Table 1 shows current compliance monitoring activities which
support the Agencywide goals for monitoring as they relate to OWEP
program objectives. For instance, in collecting the right kinds
and amounts of data (Agencywide goal) to determine and verify
permittee compliance status (program objective), OWEP uses data
from ONCRs, PCS, DMRs, CSRs, and inspections as shown in Table 1.
Objective 1; Determine/Verify Compliance Status
The NPDES compliance monitoring program relies heavily on
monitoring data generated by the permittees themselves and submitted
to State or EPA NPDES authorities on Discharge Monitoring Reports
(DMR). A significant part of this information is automated through
the Permit Compliance System (PCS). The NPDES authorities review
DMR data to determine compliance status. In addition, EPA head-
quarters reviews summary reports for each state of significant
instances of noncompliance submitted by each Region quarterly, the
Quarterly Noncompliance Report (ONCR).
EPA/State monitoring of self-reported data goes beyond the
reviewing of reports and the automating of information. EPA and
the States conduct various types of inspections to verify compliance.
These include Compliance Evaluation Inspections (CEI), Compliance
Sampling Inspections (CSI), Compliance Biomonitor ing Inspections
(CBI), Performance Audit Inspections (PAI), and Diagnostic Inspec-
tions (DI). Appendix B contains a description of each type of
inspection and the conditions under which a particular type of
inspection is performed. Moreover, OWEP conducts a DMR Quality
Assurance Program (DMR QA) which evaluates the laboratory performance
of all NPDES major permittees annually and, thereby, the credibility
of self-monitoring data.
The NPDES compliance monitoring data collected are available
on typewritten and PCS generated reports. They provide the legal
and technical basis for enforcing permit requirements.
- 2 -
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Objective 2: Reduce Noncompliance
The QNCR data drive EPA's efforts to reduce significant non-
compliance. These efforts are further directed by two major tracking
systems: EPA's Strategic Planning and Management System (SPMS) and
the Office of Water Operating Guidance and Accountabilty System
(OWOGAS). Currently, municipal non-compliance is higher than
industrial non-compliance. OWEP is managing the Agency's stategy
to deal with this priority concern through the in National Municipal
Policy,approved January, 1984. EPA/State facility compliance
inspections and periodic audits of Regional and State compliance
monitoring practices provide a check on the quality of the data
generated for the National Municipal Policy.
Objective 3: Support Permit Reissuance
Some data sources described above (PCS, DMRs, inspections,
§308 letters) support permit issuance and reissuance by providing
permit writers with background information. Permit writing is
further supported through data gathered by the office of Water
Regulations and standards for Best Available Technology (BAT).
Finally, EPA reviews all permits to ensure that their conditions
are enforceable. The reliability of OWEP data is ensured by mecha-
nisms previously described. These data are used to define monitoring
requirements, to develop effluent limits and to write compliance
schedules.
Objective 4; Monitor Pretreatment Compliance
EPA has no pretreatment compliance monitoring program in place,
even though major deadlines for compliance with pretreatment program
requirements have passed. OWEP is now developing a Pretreatment
Compliance Monitoring Program. Currently some data are contained in
OWOGAS and SPMS. Additional data will be gathered from Baseline
Monitoring Reports (BMR), Ninety-Day Compliance Reports and periodic
self-monitoring reports from industrial users of municipal collection
and treatment systems; annual reports from POTW's; and compliance
inspections of both industrial users and POTW's. Compliance monitoring
and enforcement of the Clean Water Act pretreatment requirements
will be a high priority effort for EPA.
- 4 -
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III. PROGRAM DEFICIENCIES
Currently available resources do not allow EPA and the States
to respond to all compliance monitoring needs. Major deficiencies,
numbered sequentially, are described below and summarized in Table 2
Objective 1; Determine/Verify Permittee Compliance Status
Most deficiencies in the existing program relate to the size
of the monitored universe. Current strategy focuses on the major
facilities, creating a data gap for the "minors". The extent of
the minor dischargers' contribution to toxic and water quality
problems can not now be assessed. Other program deficiencies are
data management issues. The major program deficiencies with respect
to Objective 1 are:
1. Insufficient DMR review for minors to assess overall compliance,
to determine trends, and to target enforcement actions.
2. Inadequate data on minors in PCS.
3. insufficient number of States regularly update data from DMRs,
inspections and enforcement actions in PCS. Some States and
Regional offices maintain their own data management systems
which are incompatible with PCS. Other States have no system
whatsoever. Consequently, EPA has no efficient way to identify
permittees' failures to submit DMRs or to compile reliable
statistics.
4. Reporting of compliance with enforcement orders is incomplete
and inconsistent across Regions.
5. Incomplete non-NPDES data hamper attempts to enforce regulations
promulgated under the Safe Drinking Water Act and §311 of CWA.
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In addition to having gaps in compliance monitoring data,
EPA has trouble assessing the accuracy and adequacy of data on
file. Problems arise from:
6. Insufficient number of EPA inspections to verify self-monitoring
data and permittee record-keeping.
7. Regional follow-up to problems identified by DMR QA is lacking,
restricting the ability of the program to ensure that self-
monitoring data are reliable. Moreover, DMR OA is now limited
to a few conventional parameters for major facilities.
8. Exclusion of minors and toxics from the DMR QA program leaves the
quality of self-reported toxics data open to doubt and presents
a serious data gap for a large number of permittees.
Even when adequate and reliable data are on hand they are some-
times ineffectively applied because:
9. PCS retrievals are difficult and time-consuming, particularly
for computer-shy managers.
10. Interface of PCS data with STORET and GIGS does not exist in a
form providing simultaneous on-line retrievals. The inability
to link STORET and PCS decreases OWEP's ability to establish
Water Quality impacts in enforcement proceedings.
11. Limited use of inspection data for enforcement targeting and
case support implies that available data could be better
applied.
«. "7 _.
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Objective 2; Reduce Noncompliance
The National Municipal Policy and the SPMS/OWOGAS tracking
system form the core of OWEP's program to reduce noncompliance.
After determining and verifying that a permittee is not complying
with permit conditions, EPA or the State exhorts them to comply
through both formal and informal enforcement actions.
Budget limitations prevent EPA from developing:
12. A tracking system for the National Municipal Policy. Currently
there is neither a firm baseline needs assessment nor a method
for program evaluation.
13. An adequate number of EPA inspections to verify the compliance
status of major municipal and industrial permittees annually.
14. Procedures to obtain data on municipal financial capability i n
order to verify the categorization of noncomplying POTWs required
by the National Municipal Policy.
15. Guidance on the use of available technical data in supporting
enforcement cases. Absence of such guidance contributes to
weaker cases and longer litigation times. These data should
help determine costs and schedules for remedial actio-ns and
establish environmental benefits.
Objective 3; Support Permit Reissuance
The complexity of the permitting process has been greatly
increased by the inclusion of toxics to the list of conventional
parameters requiring control. OWEP is concerned about the appro-
priateness and usefulness of current permittee self-monitoring
requirements. The major burden for the NPDES compliance monitoring
program falls on the permittees themselves. Although this issue
lies beyong the scope of this Compliance Monitoring Strategy, OWEP
will undertake a comprehensive reassessment of current regulatory
reporting requirements.
The inclusion of toxics along with the rising number of Water
Quality (WQ) limited permits and the more stringent Best Available
Technology (BAT) requirements result not only in more complex
-------
permits but also in more sophisticated treatment technologies. Many
facilities which will need more sophisticated treatment processes,
are raising increasingly complex technical and legal issues to
which permit writers must respond. Since past facility performance
forms the basis for permit reissuance, complete compliance monitoring
data are an essential process input to determine appropriate
limits and monitoring requirements. The largest database gaps
arise from:
16. Undetermined waste load allocations for toxics.
17. Inadequate criteria for protection of human health.
18. Insufficient data on pollutant removal rates, and no plan for
providing BAT/WQ-based data for permit reissuance.
One method for expediting the permit issuance process is the
General Permit. At present, OWEP has:
19. No General Permit monitoring guidelines.
20. Insufficient number of EPA inspections for data verification.
Moreover, there is no current program link between compliance
monitoring information and data on the sufficiency of permittees'
analytical methods. This lack of:
21. Integration of DMR QA data with self-monitoring data limits
effective evaluation of the quality of data used by permit
wri ters.
In addition to deficiencies in data acquisition and quality,
EPA has problems which can be traced to data management. One
problem is:
22. Insufficient coordination between Permits and Compliance groups.
For instance, EPA has no system for assuring that the Regional
or State permit writers take advantage of the compliance
monitoring data, particularly PCS.
- 9 -
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Objective 4; Monitor Pretreatment Compliance
Regulations governing pretreatment are beginning to take
effect. Under EPA's existing strategy, 1675 POTWs were identified
as needing a pretreatment program. However, EPA has significant
problems in identifying the regulated universe (POTWs, Industrial
Users) for monitoring. The pretreatment compliance monitoring
program suffers more than any other from lack of resources. At
current funding levels, there is essentially:
23. No current program to monitor compliance with both general
and categorical pretreatment regulations. EPA is unable to
determine how many Industrial Users (IU) have submitted the
required Baseline Monitoring Reports (BMR), which are the
first step in program design. Where EPA is the control
authority (in 36 States and Territories), it has no inventory
of the lUs it must regulate. The lack of technical data leaves
EPA unable to determine the potential for pollutants to
upset, pass though or interfere with POTW treatment processes.
24. Very few inspections of POTWs that have an approved pretreatment
program or, where EPA is the control authority, of lUs.
Finally, EPA has no plans to allocate resources for pretreatment
data management.
25. PCS is not funded to handle pretreatment data. The need for
efficient pretreatment program data management may not be
addressed unless PCS is modified to accommodate data on POTWs
and IDs.
IV. PLAN TO MEET COMPLIANCE MONITORING DATA NEEDS
A. Compliance Inspection Program Planning Criteria
Following are the criteria by which EPA will measure the
effectiveness of EPA and State NPDES and pretreatment program
compliance monitoring activities over the next several years. It
is unreasonable to expect resouces will be provided to meet all
- 10 -
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compliance monitoring needs. Therefore, the following criteria
describe a minimally adequate program and a basis for justifying
additional resources on an incremental basis.
EPA and NPDES States will continue to rely heavily upon self-
monitoring and reporting by NPDES permittees as the primary source
of information for assessing compliance with effluent limits and
related requirements. EPA and NPDES States will also rely heavily
upon self-monitoring and reporting by POTWs and by industrial users
of municipal treatment systems for information on compliance with
pretreatment requirements and categorical pretreatment standards.
Inspections will be conducted to verify the compliance status
of NPDES permittees, POTWs with approved pretreatment programs, and
industrial users, consistent with the following criteria:
(1) Compliance with NPDES permit requirements
(a) EPA or States will verify the compliance status of all
major permittees and PL-92-500 funded minor permittees
annually, either by inspections or by other available
informat ion.
(b) The compliance status of other minor permittees will be
verified as resources allow.
(2) Compliance with pretreatment requirements
(a) EPA or States will verify the compliance status of POTWs
with approved pretreatment programs annually, either by
inspections or other available information. This verifica-
tion will normally be done in conjunction with NPDES
compliance verification, for the affected POTWs.
(b) The compliance status of primary industrial users, where
EPA is the control authority, will be verified annually.
(c) The compliance status of other industrial users, will be
verified as resources allow.
- 11 -
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EPA aod States will cooperatively develop compliance inspection
plans (CIPs) for each State as part of the §106 program planning
process. The CIPs will include facility specific commitments for
inspections by the State or EPA and will designate the type of
inspection planned for each facility. The CIPs will delegate
responsibility for reporting the results and for entering inspection
data in PCS.
EPA expects that approved NPDES States will take the lead in
the planning and implementation of CIPs; EPA will take the lead
role in non-NPDES States. Over the longer term the Agency will
expect NPDES States to assume full responsibility for both the
planning and performance of their compliance inspection programs.
The end result will be the elimination of EPA-funded inspections
in the NPDES States except where a State lacks the necessary
expertise to perform a specific, specialized inspection.
However, at least through FY 1986, EPA will continue to cooperate
fully in the design of CIPs and to supplement NPDES State inspection
resources as needed. In this regard, EPA's expectations of the
State compliance inspection programs will depend upon whether the
State has both an approved NPDES program and pretreatment enforcement
program or just the NPDES program.
In response to Regional and State needs, OWEP is developing
inspection targeting criteria that will use information obtained
from available sources. Of prime importance will be data from
the QNCRs and the DMR OA program. in addition, information on
permit reissuance targets and pretreatment program needs will
be used to target facilities for specified types of inspections.
The major focus will be facilities with toxic parameters in their
permit and facilities funded under PL92-500.
Significant non-compliance with final effluent limits or
compliance schedules will be important criteria for targeting
CEIs. Permit reissuance and enforcement case support will be
criteria for targeting CSIs. The DMROA program will pinpoint
facilities which would benefit from a PAI. A Diagnostic Inspection
(DI) will be performed at federally funded facilities who fail to
meet permit conditions or construction deadlines. EPA will
strive to improve the efficiency of inspection targeting and to
conduct as many specialized inspections as needed without reducing
the total number of facilities inspected.
- 12 -
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B. Proposed Activities
The activities that OWEP proposes in order to overcome the
deficiencies identified above are described in Table 3, sequentially
numbered for easy comparison with Table 2. They can be divided
into three levels of priority:
Priority 1: Activities that are currently scheduled to begin in
FY 84, but have inadequate funding.
Priority 2: Activities that are unfunded but are needed to meet
current Agency needs.
Priority 3: Activities that are unfunded but are needed to meet
future Agency needs.
The priority level and resource needs for each activity listed in
Table 3 are identified in Appendix A.
Priority 1; Activities Currently Scheduled
OWEP's plans to upgrade EPA's ability to determine and verify
compliance centers on improving PCS. System efficiency is being
increased by conversion to an agencywide data base management
system called ADABAS; on-line retrievals are being facilitated by
INQUIRY. PCS is expanding to include data on non-major facilities
from all States. In addition, there are plans to improve coordina-
tion between the Regional Environmental Services Division personnel
and the Water Division Enforcement staff and to track municipalities
identified in SPMS by State Municipal Compliance Strategies.
To support permit reissuance, OWEP has planned activities to
expand the technical database. Complex effluent testing is scheduled,
as is the development of Technical Support Documents which will
deal with biomonitoring. At current funding levels, the only
activity to monitor pretreatment will be providing general guidance
on implementing regulatory requirements.
- 14 -
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Priority 2; Activities Required to Meet Current Needs
OWEP proposes to close the data gaps through two mechanisms:
increasing the number of inspections and expanding compliance
monitoring to minors.
Significant progress is being made in developing inspection
protocols and manuals; the need now is implementation. By conducting
more inspections, by targeting them more effectively (e.g., through
follow-up to DMR QA data) and by better coordinating State-EPA
efforts, EPA can make great strides in upgrading its compliance
monitoring program.
In addition to high quality inspection data, OWEP needs to
fill in the "blanks" on minors. EPA and the States will extend
compliance monitoring coverage to a representative sample of
minors and to "problem" minors. PCS will be expanded to include
this group of minors. OWEP is developing a method for using a
statistically valid random sampling of minors to estimate compliance
rates at minimal cost.
Also, to support permit issuance/reissuance, expanded technical
input will be provided for adjudicatory hearings and for decision
making on permit requirement variance and waiver applications.
Finally, EPA must address pretreatment compliance monitoring.
Besides incorporating pretreatment into inspection scheduling,
the OWEP proposes to begin systematically collecting data on
both POTWs and lUs where EPA is the control authority, and on
primary industrial users of POTWs not now in the regulated universe.
The data will become part of PCS.
Priority 3; Activities Required to Meet Future Needs
The extent of future needs is not currently known. However,
OWEP must continue to revise and improve its compliance monitoring
program. OWEP will initiate an in-depth study of options for
direct data system interfaces so that EPA can take advantage of
data stored not only in PCS, but also in such data bases as
STORET and GICS.
- 15 -
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OWEP will also conduct a study and provide guidance on
financial capability issues related to establishment and enforcement
of compliance schedules for POTWs that need to construct facilities
to comply with permit requirements. Finally, OWEP will provide
guidance on compliance monitoring of "general permittees" and for
support of non NPDES enforcement under §311 and §404 of CWA.
V. RELATION TO OTHER MONITORING PROGRAMS
At this point, NPDES compliance monitoring is not actively
coordinated with other monitoring programs. OWEP is interested in
developing guidance on field practices to coordinate compliance
monitoring with ambient monitoring. In particular, specialized
inspections should be performed in conjunction with intensive stream
surveying. Data reporting and management should also be coordinated.
PCS could become a focal point of program integration.
The PCS data base is available to many EPA offices
and NPDES States. NPDES States that put data into PCS have full
access to the data they enter. EPA Regions have access to the
entire national data base. OWEP Headquarters also has access to
the national data base. Moreover, any Headquarters EPA Office with
an account at the National Computer Center (NCC) can access PCS.
This is done frequently.
Members of the public making requests under the Freedom
of Information Act can obtain a hard copy of any data in the system
that they request. Members of the public, however, cannot simply
tap into PCS. An account at NCC is required, and that is available
to EPA and some other Government Agencies. (Other agencies with
an NCC account, therefore, can access the system).
As noted earlier, there is a need to coordinate PCS compliance
monitoring data with data on water quality maintained by OWRS
(STORET) and data on construction grants (available in GICS).
The development of an interface between the three systems is
among the activities proposed in Tables 3 and Appendix A.
EPA's Office of Enforcement and Compliance Monitoring is
charged with compiling multimedia compliance statistics. While
not a direct coordination, this activity will improve the integration
of compliance data information systems across all media.
- 16 -
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VI. TECHNICAL BARRIERS, ISSUES AND OPPORTUNITIES
The NPDES compliance monitoring program deals with a large
number of technical and legal requirments. Three areas of technical
concern emerge:
1. Analytical Methods Development, Including Biomonitor ing
Section 304(h) of the Act requires that EPA develop, approve,
and publish analytical methods and procedures for sampling and
analysis of pollutants which are limited in NPDES permits. EPA
must also review alternative procedures proposed by permittees.
Approval of alternative procedures requires, in addition to a
detailed review of protocol, demonstration of equivalency with an
approved or standard method. A major problem in this effort has
been the lack of progress in regulatory reform. EPA's Office of
Research and Development has yet to promulgate regulations to
simplify procedures and decrease the number of permittees requiring
approval for alternate analytic methods.
EPA has recently developed a new biomonitoring procedures to
measure chronic toxicity. If site-specific studies now underway
succeed, these procedures will become permit requirements for
toxic dischargers.
2. Complex Permit Reissuance, Including Pretreatment Requirements
The permitting process has been complicated by regulatory
demands for more sophisticated treatment systems (BAT, BCT, and
WQ permits) with which the public has limited expertise. Some
permittees impose special ambient monitoring data needs, such as
POTW marine dischargers with §301(h) variances. The need for
more complicated inspections taxes EPA and State capabilities.
In addition to more sophisticated systems, permit writers must
now deal with a longer list of parameters. The inclusion of
toxic chemicals in facility permits creates needs for biomonitoring
requirements for which analytic methods are still under development.
The underlying physical phenomena, e.g. how toxics bioaccumulate
and pass through the food chain, are not well understood.
- 17 -
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EPA lacks expertise in pretreatraent compliance monitoring
while POTWs seek technical guidance on how to determine technically
defensible self-monitoring requirements for lUs. The few EPA
pretreatment inspections now performed are done by an outside contractor
There is niether a guidance document nor a manual for conducting
pretreatment inspections.
3. O&M Procedures
Operation and maintenance problems are a major cause of munic-
ipal noncompliance. As new and innovative technologies come on
line, continued efforts are needed to improve plant efficiency.
In addition, aging wastewater collection and treatment systems
pose special O&M problems.
VII. RESPONSIBILITIES OF HEADQUARTERS, REGIONS, STATES AND PERMITTEES
Headquarters oversees and coordinates regional activities, provides
technical assistance to regional offices upon request, and develops
policy, guidance and regulations.
Regional Office implements policy, guidance and regulations in non-
delegated States, oversees and coordinates activities in delegated
States, and provides technical assistance to States.
States, which are delegated the NPDES program, monitor permittees
and implement the NPDES program. In non-delegated States, these
responsibilities are assumed by the Regional Office, with States
providing input on a case-by-case basis.
Permittees provide self-monitoring data.
Additional discussion of EPA/State responsibilities is provided in
Section IV of this Strategy.
- 18 -
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SECTION 1
MONITORING GOALS AND OBJECTIVES AND
ENVIRONMENTAL INFORMATION NEEDS
Program Goal
The scope ot the ocean monitoring strategy is marine waters
impacted by human activities, especially those of regulatory
interest. The strategy does not address more general ambient
ocean monitoring since this is considered a function o£ the
National Oceanic and Atmospheric Administration (NOAA). There
are four major goals of the Oceans Monitoring Strategy. Although
other areas could be addressed, the strategy will be limited in
scope to these four goals.
The first goal is to identify current and future data
requirements for each EPA ocean program. In-depth interviews
with EPA ocean program managers will be held to evaluate
on-going monitoring and future data needs for new sites
of investigation.
The second goal is to design a monitoring program that
stresses the quantitative analysis of impacts in terms of
statistical validity, quality assurance and experimental design.
The Marine Protection Branch of the Criteria and Standards Division
has initiated a work effort to address these concerns as related
to monitoring conducted from the OSV Antelope.
The third goal is to evaluate the various data collection
efforts and to determine whether commonality exists in terms of
area of study, data collected, statistical analysis or data
reduction. Standardization of areas of commonality will be
completed to enhance overall data collection efforts. This will
be of importance to programs such as 301(h) involving monitoring
around marine outfalls from Publicly Owned Treatment Works. The
data collection by the regions and headquarters for this program
needs to be coordinated and standardized.
The fourth goal is to document, systematically, how one can tap
into all available data collection activities (current and past)
when looking at a new ocean site, that is, a site not previously
considered in conjunction with regulatory activities. The Ocean
Programs Branch of the Criteria and Standards Division is presently
investigating federal data sources pertinent to various EPA
ocean programs. An automated system is under development for
the transfer of some of this information. An investigation of
non-federal data bases pertinent to EPA programs will be conducted.
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- 2 -
SECTION 2
THE EXTENT TO WHICH THESE NEEDS ARE NOW BEING MET
1. Identification of Data Requirements
The first goal is to identify current and future data
requirements for each EPA ocean program. Based on preliminary
interviews with EPA ocean program managers, many offices
expressed a need for biological, physical and chemical
information for certain locations. Currently, this information is
obtained through literature searches by contractors and/or from
other agencies and organizations. A substantial portion of this
information is obtained from non-EPA sources. In some cases,
EPA does conduct monitoring from the OSV Antelope to fulfill
data needs for certain programs.
Although general data requirements appear similar, specific
data requirements differ because of the differences in program
purposes. Some specific purposes for monitoring are:
(1) Issuance of waste disposal permits other
than dredged materials,
(2) Enforcement action,
(3) Establishment of criteria for regulating waste
disposal,
(4) Site designation and management,
(5) Overall ocean disposal management, and
(6) Research on alternative ocean disposal techniques.
More in-depth interviews will be held with the program managers
to obtain future site information needs such as specific biological,
physical and/or chemical parameters required to fulfill the purposes
of each regulatory program. This information will be used to
complete Goals 2, 3 and 4.
2. Improvement of Monitoring to Meet Data Requirements
The second goal is to evaluate data collection efforts and
determine if they are adequate for intended purposes, for example,
management of ocean disposal sites. The objective is to develop
a field monitoring program that is scientifically and statistically
based.
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- 3 -
The Marine Protection Branch of the Criteria and Standards
Division is responsible for the monitoring effort by the OSV
Antelope. Other data is collected at ocean dumping sites by NOAA,
the Corps of Engineers, and the permittees as part of the permit
requirements but the thrust of this task will only be to re-evaluate
the current Antelope monitoring strategy.
The Antelope's monitoring program is currently being evaluated
in terms of organizing its data collection system from the survey
planning phase, to the QA/QC procedures used onboard the ship, to
report preparation and site management based on field-collected
environmental data.
The original data collection for the ocean dumping program was
for the purpose of site designation and generation of EIS's.
This data was all contractor-gathered and the raw data and computer
software was not readily available to EPA. Data summaries and
much of the data that had been input to the system were, however,
available. No work has been done to analyze the usefulness of
this data in regard to format or compatibility with existing EPA
computer capability.
Since EPA has taken over responsibility for site surveys, the
program has been implemented on a site-by-site basis with the
aid of the regions. The results have been reported in separate
documents and no attempt has been made to integrate data between
sites and no synthesis over a long time period has been accomplished
for any site.
For two reasons the program office has decided that, although
the site monitoring program should be tailored to individual
sites, a broader view, yet more directed view, and a method of
data base storage and manipulation was becoming essential. The
first reason for needing increased data tracking and control is
the sheer volume of data that is generated during each survey.
For example, a two week survey collected 292 grain size samples,
each of which generated 15 separate data points as size percentages.
On a single survey, 295 polychaete taxa were represented by
6,195 individuals.
The second reason is a new policy position agreed upon by
the Corps and EPA. For sites in the process of designation or
those that have been designated (the "consent agreement sites") a
monitoring plan will be provided at EPA headquarters level.
This plan will be based on information in the EIS for that site
and will specifically define what criteria will determine when
the site will be rested (temporary cessation of dumping while
recovery occurs) or terminated (or other management options
as they become available) and will specify the significant
adverse environmental effects at the site. In the future,
management of the sites will be based on the field monitoring
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- 4 -
program results, as well as ancillary information generated in
support of the permit program. For the remainder of the non-consent
agreement sites, the EPA Regions will be responsible for site
designation and the monitoring/management strategy.
In both cases, data comparability, quality assurance/control,
data tracking, and storage and manipulation must be addressed at a
central location and handled in the same manner to ensure program
reliability. When a management program is based on potentially
subtle impacts that must be addressed in terms of temporal and
spatial variability, systematization is the first important factor
to be addressed.
The program office, for the above reasons, has started on a
comprehensive program to re-evaluate its previous approaches to
monitoring and to evaluate new approaches in view of changing
program goals.
On February 14-15, 1984, a technical workshop was held in
Annapolis, Maryland on monitoring techniques and strategies. The
attendees included representatives of other government agencies,
the private sector (contractors), and universities, as well as the
headquarters and regional persons involved with the ocean dumping
program. All the attendees were experts and/or were actively
involved in ocean monitoring/management. A summary of the work-
shop proceedings will be available in mid-April.
The workshop looked at techniques for their applicability
to the goals of the program. It was noted during this meeting
that the level of sampling intensity, replication, and data
analysis were under question. For this reason, a separate task
has been instituted to recommend methods to improve these concerns.
In 1980, the original contractor for the dump site survey
program finalized his QA/QC procedure for shipboard operations.
After that program was terminated, EPA took control of the
survey program and used that manual as the basic QA/QC document
for its survey work. However, since 1980, many new and significant
pieces of equipment have been added to the ship and many new
procedures have been instituted. In order to bring this important
document up-to-date and to ensure some consistency throughout
the surveys, even when different crews are onboard, a new manual
was contracted. A draft was delivered in February and is undergoing
internal review. It is very important that not only data analysis
be as standard as possible taking into account differing oceanic
regimes and site requirements, but that the collection of this
data in the field be as uniform as possible. The draft will be
available for a wide review in May.
The development of a quantitative impact assessment program will
take place over the next few months as described in Section 3.
The program will consist of three parts:
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- 5 -
Part I- Analysis of Historical Data (from existing EIS or general
literature)
A. For both new sites and designated sites
(1) Explain how existing site specific data (EIS) or
literature data (regional) can be assessed for
suitability for defining the ecosystem.
(2) Define the goals of the monitoring program
based on the potential impacts at the sites.
0 Identify whether the design of the monitoring
program will need to take into account a
reconnaissance effort.
0 If the program needs little, if any, new data
to design the monitoring portion of the program,
the existing data is analyzed for major (temporal
or spatial) sources of variation in the
environment at the site.
Part II-Reconnaissance Sampling
A. For new sites
(1) Undertake spatially extensive, unreplicated sampling
over the study area to:
0 Define the general over-all structure of. the
particular biotic community or geochemical
assemblage of interest.
0 Identify the spatial variation in the study
area for biological and geochemical parameters.
o
Determine the relationship of components of the
assemblage (e.g., taxonomic, trophic, or geochemical
groupings) to important natural covariates (e.g.,
sediment grain size, salinity, depth) in the system.
Using statistical analysis techniques, determine
if there is any quantifiable relationship between
parameters measured.
0 Identify "potentially important" or "indicator"
species or other taxonomic indicators of impact.
(2) Confirm or determine the statistical nature of the
data (within-station heterogeneity) by collecting
replicate samples for biological, geochemical, and
environmental parameters at carefully selected
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- 6 -
stations representing the range of conditions expected
over the study area (e.g., the range of sediment types)
(3) Incorporate the data from the reconnaissance sampling
into a developing Project Data Base.
(4) Synthesize all data for optimization of the Phase III
sampling design. Synthesis enables different types
of data with differing dimensions to be compared and
manipulated statistically.
B. For sites that have an EIS and have been proposed for
designation. (Sites for which there is replicated data.)
(1) Confirm or determine the statistical nature of the
data (within-station heterogeneity) by analyzing the
replicate survey smples for biological, geochemical,
and environmental parameters at carefully selected
stations representing the range of conditions over
the study area (e.g., the range of sediment types).
In this case replicate data exists although it has
not been analyzed statistically.
(2) Using the data in the EIA:
0 Define the general over-all structure of the
particular biotic community or geochemical
parameters of interest at the site.
0 Identify the major sources of spatial variation
in the study area for populations and communities
of interest as well as for important environmental
covariates. In other words, does the existing
data already tell us what impacts have occurred
at the site and can these impacts be attributed
to disposal materials.
0 Determine the relationship of components of the
assemblage (e.g., taxonomic, trophic, or geochemical
groupings) to important natural covariates (e.g.,
sediment grain size, salinity, depth) in the
system. Can the impacts be related in a
quantifiable way to parameters that can be
measured in the monitoring program?
0 Identify "potentially important" or "indicator"
species or other taxonomic indicators of impact.
A few species can be identified to watch because
of their sensitivity to the parameters that can
be expected to change with disposal.
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-J
(3) Determine whether additional data from another sampling
survey may be needed for developing Project Data Base.
(4) Synthesize all data for optimization of the Phase III
sampling design for quantitative impact sampling.
0 Provide recommendations for design changes to
optimize information/cost ratios.
Part Ill-Impact Assessment Sampling
A. The impact assessment program will be designed
differently from the reconnaissance program. It
will be spatially less extensive but will be more
intensive at particular stations and sampling strata.
(1) Statistically and experimentally control extraneous
variance and influence of covariates on group means
for variables of interest. After the species and
parameters of interest are selected, make sure they
will remain independent of non-essential parameters
to fulfill the monitoring requirements.
B. Hypotheses will be defined and tested, for example,
"is the site similar to areas not influenced by dredged
material disposal in community structure?"
(1) Test hypotheses regarding the standing stock
(biomass, abundance or concentration) for various
geochemical and biological parameters. Select
parameters that will vary with impacts and measure
impacts in a statistically valid manner.
C. From the hypothesis testing can come decisions on
"real-world" patterns.
(1) If. the hypotheses indicate an impact is occurring
and the possibility of the measurements undertaken
are defensible, quantifiable statistically and
are not due to environmental variability, the
site manager has his data to support his site
management decisions.
3. Areas of Commonality in EPA Ocean Monitoring
The third goal is to evaluate the various data collection
efforts and to determine whether commonality exists in terms of
areas of study, data collected, statistical analysis or data
reduction.
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- 8 -
The EPA programs involved in ocean monitoring include 301(h),
Ocean Dumping, 403(c), NPDES Permit Program, Radiation Program,
and perhaps others to a lesser degree. Basically the ocean
monitoring is for the following reasons:
301(h) allows the issuance of an NPDES permit with
modified secondary treatment requirements for discharges
from a POTW if the discharge is into ocean or estuarine
waters and the discharge will not interfere with a balanced
indigenous population. The monitoring is for determining
the impact of the discharge on this "balanced indigenous
population."
Ocean Dumping is the transport of materials for the pur-
pose of disposal in the oceans. There is very extensive
survey monitoring in this program for site designation;
later surveys are conducted during dumping for permit
compliance and also even after a site is no longer used.
403(c) Ocean Discharge Criteria requires monitoring if a
permit is to be issued without a finding of "no unreason-
able degradation". Monitoring may be required specifically
to resolve the unknowns. This program will be utilizing
all monitoring results in their automated Data Management
and Decision System.
Office of Radiation are involved in monitoring of ocean
sites where radioactive materials have been dumped or
possible future disposal of contaminated materials.
Permits Division-Monitoring involves permit compliance
(DMRs); special monitoring studies (usually performed by
permittee in lieu of more stringent conditions), and
monitoring associated with 403(c) and 301(h)(see above).
The existing and future geographic areas to be covered by
the monitoring program will be identified and any overlaps will
be noted. Currently, the programs monitoring activities occur
at various locations; nearshore, on the outer continental shelf
and sometimes beyond. For instance, the 301(h) program monitors
municipal outfalls close to shore, whereas NPDES permits might
require monitoring beyond the 200 mile Exclusive Economic Zone
(EEZ) for deep seabed mining. If there are overlaps, programs
can be coordinated to ensure an efficient use of the resources
at the site.
Also, a data matrix will be developed which identifies the
type of data being collected by the various programs. The type
of information collected will vary depending on program needs or
the regulatory stipulations. Most programs will gather descriptive
information on the physical environment (i.e. temp, salinity,
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etc.). Some will be concerned with the biota at the site while
still others may be interested in toxic pollutants accumulating
in the sediments. This data matrix will help identify any overlap
of sampling activity.
The purposes of the data collection efforts will be described.
Data not used will be investigated to determine whether data
collection should continue for this parameter. After the
development of the data matrix, the data reduction techniques
will be reviewed to determine whether commonality exists across
the programs. Recommendations will be made for these statistical
areas of overlap.
A current area of interest is the monitoring data collected
as part of the 301(h) program. The major issues are where the
data should be stored (BIOSTORET or NODC) and what data format
should be used. Both of these issues will be investigated as
part of this goal.
The newly formed Program Systems Task Force of the Monitoring
and Data Support Division will work with the Office of Marine
Discharge Evaluation to ensure that the data collected under
the 301(h) monitoring programs is stored in formats that allow
integration with other related data and that facilitate analysis
using readily available analytical packages. Under no circumstances
will data systems be developed that duplicate existing capability.
Every effort will be made to adapt existing data systems to the
new requirements of 301(h).
The output products from this effort should include, besides
a report discussing the identified objectives, the following:
0 a detailed description of EPA's Ocean Monitoring programs.
0 a series of maps with overlays to show either location
of program activities or elements of monitoring efforts.
0 a series of matrices or tables indicating types of
monitoring data collected, schedules, statistical data
reduction techniques, etc.
0 overlaps, redundancies or gaps.
0 recommendations for future monitoring efforts, scheduling,
and cooperation.
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4. Accessibility of Ocean Data
The fourth goal is to document, systematically, how one can
tap into all available data collection activities when looking
at a new site.
The Ocean Programs Branch of OWRS is currently evaluating
federal data sources pertinent to EPA ocean programs. Also, the
National Oceanographic Data Center (NODC) of NOAA is developing
an Ocean Pollution Data and Information Network (OPDIw). The
goals of tbi?3 nQ*-w>rk *re>. to:
(1) T"ipro"» t-hp> ^rcessi hi lity and usefulness of federal
ocean pollution data and information to both federal
and non-federal users;
(2) Strengthen federal interag^nry communication regarding
ocean pollution data and information, a^ well a^ state,
regional and private sector aw^r^nosc of these resources
NODC has interviewed 66 coordinators of ocean data in the
federal government of which severa] w^r^ in ^PA headquarters, regions
and laboratories. The second phase of this project involves inter-
viewing non-federal ocean data base coordinator?. Thi<^ xvill be
on-going through fiscal year 1984.
We plan to submit the necessary information 0*1 all o^ EPA's
data collection efforts to the OPDIN project managers for inclusion
in their handbook on federal systems. For those EP°i data needs
that are not fulfilled by existing f^d^ral data bases, we will be
coordinating with NODC to determine if the data needed is
available from non-federal organizations. Program data needs that
are not met by the data bases under study by NODC but which are
met by other data bases will also be investigated. It such cases
exist, we will recommend that NODC include these data bases in
their on-going study.
Data bases that are relevant to EPA program needs will be
investigated to develop a procedure to facilitate the transfer
of the information. The procedures will be outlined in this
study for each data base of interest. Part of this effort is
currently underway by the Ocean Programs Branch as discussed
earlier.
Also, for those ocean programs which will be investigating
new locations, we will outline the available federal and non-
federal sources of pertinent information. The procedures tor
accessing the data or transferring the data will also be discussed
in detail in this study.
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SECTION 3
PROGRAM PLAN FOR MONITORING TO MEET FUNDAMENTAL DATA NEEDS
The following program plan outlines the work schedules for
each of the four goals discussed earlier.
GOAL 1; Identification of Data Requirements
The first goal is to identify current and future data
requirements for each EPA ocean program.
Estimated
Work Plan Elements Date of Completion
1. Conduct in-depth interviews with July 13, 1984
EPA ocean program managers to
evaluate on-going monitoring and
future data needs for new sites
2. Evaluate data collection in August 10, 1984
relationship to program purposes.
Identify any additional data
needs not fulfilled by existing
data bases.
3. Write a summary report on the August 31, 1984
findings
GOAL 2: Improvement of Monitoring to Meet Data Requirements
The third goal is to evaluate past and proposed data collection
efforts with a view toward planning quantitative approaches to
management of ocean dumping sites.
Estimated
Work Plan Elements Date of Completion
1. Technical Workshop on Monitoring February 14-15, 1984
Surveys
2. QA/QC Document in draft February 24, 1984
submitted to headquarters
3. The first of three meetings April 3, 1984
on quantitiative monitoring
strategies will be held at
headquarters. The purpose of
the meeting will be to refine
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the goals of the site management
program in relation to an active
site monitoring effort.
4. The second of three meetings
on monitoring strategies will be
held at headquarters in Mid-April.
The contractor will present a draft
report on experimental design and
data management and analysis geared
to the specific requirements of ocean
dumping dredged material dump site
management. This report will be
circulated for review to other EPA
program offices, the regions and
laboratories.
5. Draft quantitative impact assessment
circulated to headquarters and COE
headquarters for review and comment.
6. The third of three meetings on
quantitative impact assessment will
bring together regional and
laboratory people, headquarters,
and contractor personnel for a
review of the draft report on
quantitative approaches to
management.
7. The draft report on QA/QC
procedures will be circulated
to regions for comments.
8. The final report on quantitative
approaches to site-specific
monitoring will be produced.
9. Recommendations on format of
data base of historical Antelope
data.
10. Determination on system software
availability of a program data base*
11. The final report on QA/QC procedures
will be produced
May 14, L984
May 14, 1984
June 18, 1984
June 7, 1984
July 13, 1984
September 30, 1984
September 30, 1984
August 10, 1984
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- 13 -
12. Input data for Antelope surveys
* Partially completed December 1983 under task order
December 28, 1984
Feb. 15, 1985
GOAL 3; Areas of Commonality in EPA Ocean Monitoring
The third goal is to evaluate the various data collection
efforts and determine whether commonality exists in terms of areas
of study, data collected, statistical analysis or data reduction.
Work Plan Elements
Estimated
Date of Completion
1. Determine if overlaps of geographic areas of
interest occur between the follow programs:
September 21, 1984
a. 301(h) - 583 applications
b. EIS data - 29 sites completed
66 sites need more work
c. Oil and gas leases in coastal and
offshore area
d. Antelope sites or transect areas
e. Ocean Thermal Energy Conversion (OTEC)
area
f. Deep Sea Bed Mining
g. Hard Mineral Resource
h. Radioactive Materials
i. Activities in state waters such as
those covered under Section 404 or
403(c) other than those listed above
2. Develop matrices or table indicating
the types of monitoring data collected,
schedules, statistical data reduction
techniques, etc.
3. Identify overlaps, redundancies or gaps.
October 27, 1984
November 23, 1984
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- 14 -
4. Prepare recommendation for future August 31, 1984
monitoring efforts, scheduling and
cooperation.
GOAL 4; Accessibility of Ocean Data
The fourth goal is to document, systematically, how one can
tap into all available data collection activities when looking
at a new site.
Estimated
Work Plan Elements Date of Completion
1. Meet with NODC representatives to discuss October 27, 1984
EPA's existing and future data requirements
and determine whether data bases in their
survey could meet these needs. Evaluate
both NODC's "F" and "C" Files.
2. For those EPA data needs not fulfilled by November 9, 1984
existing federal or non-federal data
bases in the NODC study, determine if any
other sources are available.
3. If other sources have pertinent data, December 7, 1984
request that the data bases be included
in the NODC survey. Otherwise, include
these data needs as new monitoring
requirements under the first goal
of this strategy.
4. For those EPA data needs fulfilled by December 28, 1984
existing federal and non-federal data
bases, develop and document a procedure
to facilitate the transfer of the
information.
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SECTION 4
MONITORING DESIGN, SAMPLE HANDLING, CHEMICAL ANALYSIS,
DATA ANALYSIS AND DATA PROCESSING
SECTION 5
LINKAGES WITH OTHER PROGRAMS INCLUDING MONITORING PROGRAMS
CRITERIA AND STANDARDS, RISK ASSESSMENT AND ENFORCEMENT AND
LINKAGES WITH OTHER FEDERAL AGENCIES
SECTION 6
TECHNICAL BARRIERS, ISSUES, AND OPPORTUNITIES
SECTION 7
ROLES AND RESPONSIBILITIES OF VARIOUS HEADQUARTERS OFFICES,
THE REGIONS AND STATES INCLUDING LOCAL PROGRAMS
SECTION 8
DATA MANAGEMENT AND DATA ANALYSES
SECTIONS 4-8 will be completed after implementation of. the program
plans outlined in Section 3.
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SECTION 9
A SCHEDULE FOR IMPLEMENTATION
This section will list the time required for completing
the activities discussed in this strategy. Specific goals
discussed here include:
GOAL 1 - Identification of Data Requirements
Staffing
This task would require approximately 1/4 man-year of EPA
staff time.
GOAL 2 - Improvement of Monitoring to Meet Data Requirements
Staffing
This goal is expected to cost the following, excluding the
reports already in progress:
A. Two contractor man-years at $60,000 total. This estimate
is based on two technician keypunchers working six months
apiece, and one half man-year of programming. The last half
man-year is additional support of regional integration into
the program.
B. One person at headquarters will be needed full-time to
interface with data entry, retrieval planning, and regional
interests.
GOAL 3 - Areas of Commonality in EPA Ocean Monitoring
Staffing
This task would require approximately one man-year of
contract effort at a cost of $60,000.
GOAL 4 - Accessibility of Ocean Data
Staffing
This task would require approximately 1/2 man-year of
EPA staff time and some contract funding for NOAA to add
new data bases to their list of data bases to be surveyed,
if necessary.
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DRINKiNG UURT6R
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CONTENTS
Page
I. INTPODUCTION 1
II. SUPPORT FOR STANDARD SETTING - PUBLIC WATER SUPPLY SYSTEMS 3
A. Goals and Objectives 3
B. Extent to Which Needs are Being Met; Monitoring Plans 4
National Inorganics and Radionuclides Survey
National Pesticides Survey
Data Handling
Quality Assurance Aspects of Surveillance and
Monitoring for Standard Setting
C. Data Handling 6
D. Quality Assurance Aspects of Surveillance and Monitoring 6
for Standard Setting
III. EVALUATION OF SYSTEM COMPLIANCE WITH DRINKING WATER STANDARDS 7
A. Goals and Objectives 7
B. Quality Assurance/Quality Control 8
C. Extent to Which Data Needs are Being Met 9
D. Data Analysis 10
IV. CONTAMINATION INCIDENTS 11
A. Goals and Objectives 11
B. Extent to Which Needs are Being Met 12
C. Plan to Meet These Needs 13
V. UNDERGROUND INJECTION CONTROL PROGRAM 14
A. Goals and Objectives 14
B. Quality Assurance 15
C. Extent to Which Needs are Being Met 16
VI. OTHER MONITORING ACTIVITIES 16
A. General Technical Assistance 17
B. Monitoring by Regional Laboratories 18
C. Monitoring in Support of the Sole Source Aquifer 18
Program
D. The Surface Impoundment Assessment 19
E. The Rural Water Survey 19
VII. DRINKING WATER PROGRAM - MONITORING INITIATIVE RESOURCES 21
A. Introduction 21
B. Current Level of Effort: FY 1985 Budget Request 22
Expanded Definition of Monitoring
Limited View of Monitoring
C. Enhanced Level of Effort: FY 1986 Budget Request 27
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APPENDICES
A. Constituents Evaluated in the National Inorganics and 31
Radionuclides Study
B. National Interim Primary Drinking Water Regulations oo
C. Future Standards
Revised Primary Drinking Water Regulations 35
Phase I: VOCs Under Consideration for Regulation 36
Phase II: Fluoride 37
Phase III: Radionuclides 38
Phase IV: Disinfection By-Products 38
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MONITORING STRATEGY
OFFICE OF DRINKING WATER
I. INTRODUCTION
The Safe Drinking Water Act provides for the safety of drinking water
supplies by the establishment of national drinking water quality standards. Under
the Act, EPA has the responsibility for establishing the national standards and
the States are responsible for enforcing them. Major provisions of the Act include:
the establishment of enforceable primary regulations for the protection of health;
non-enforceable secondary regulations relating to taste, odor, and appearance of
drinking water; measures to protect underground drinking water sources and variances
and exemptions, among others.
Section 1445 of the Act explicitly authorizes the Administrator to require
monitoring for a wide variety of purposes, namely: establishing and determining
compliance with regulations; administering financial assistance; evaluating
health risks of unregulated contaminants, and advising the public of such risks.
Monitoring authorization is also implied in Section 1450(a)(l), which grants to
the Administrator broad authority to prescribe such regulations as are necessary
or appropriate to carry out his functions. For convenience, monitoring activities
pursuant to these authorities may be grouped into five broad categories:
0 Support for standard setting
0 Evaluation of system compliance with drinking water standards
0 Monitoring associated with contamination incidents
0 Underground Injection Control Program monitoring
0 Other Monitoring Activities
Support for standard setting involves those activities necessary to determine
the extent to which contaminants are found in finished drinking water and in the
sources of the raw, untreated water. These data are used to estimate the number of
people exposed to the contaminant and the health implications, which depend on the
level and duration of exposure. They are critical inputs to standard setting.
Evaluation of system compliance entails the collection and analysis of data on
violations of drinking water standards and what the cognizant authorities are doing
to correct the situation. These data are the main tool for managing and evaluating
the drinking water program.
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Monitoring associated with contamination incidents involves, as the title
implies, the surveillance of contaminants associated with a specific event like a
chemical spill or leaking hazardous waste dumps. It differs from support for
standard setting in that this type of monitoring generally involves random sampling
intended to statistically determine the nation-wide extent of contamination, while
contamination incident monitoring is carried out in connection with known localized
incidents of contamination, usually following the discovery of a contaminated
well.
Monitoring conducted under the Underground Injection Control program is
intended to ensure that injection wells are being operated properly so that contami-
nants do not migrate into underground sources of drinking water.
In addition, other types of monitoring activities or special studies are
conducted to address specific needs, or at the direction of the Congress. Examples
of other types of activities are, General Technical Assistance; Monitoring by
Regional Laboratories, and Monitoring in support of the Sole Source Aquifer (SSA)
program. Special studies conducted by the Office of Drinking Water (ODW) are
exemplified by the Surface Impoundment Assessment (SIA) and the Rural Water Survey.V
In all programs involving the acquisition of environmental data, the Office of
Drinking Water is committed to a vigorous quality assurance (QA) program which
involves the preparation of detailed QA plans and standard operating procedures
for sampling, analytical and data handling procedures.
I/ Another study of relevance to drinking water quality, being conducted by the
Office of Pesticides and Toxics Substances, deals with leaking underground
storage tanks (the "LUST" study).
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II. SUPPORT FOR STANDARD SETTING - PUBLIC WATER SUPPLY SYSTEMS
A. Goals and Objectives.
The goal of this activity is to provide occurrence data on contaminants under
consideration for standard-setting for the Public Water Supply Program. The data
are used to help determine whether the contaminant occurs sufficiently frequently
and at high enough levels that setting a standard is warranted; to estimate
national economic impact of prospective regulations, and to estimate the reduction
in exposure that would result from regulation. In the case of carcinogens, the data
enable us to project the reduction in excess cancer deaths.
We collect drinking water samples in national surveys which we design and
manage. We would like to use existing State data but have not been able to do so
because we require samples from surveys designed to enable us to statistically
project the results to national totals. This cannot be done with State data because
such data, which result from the investigation of specific contamination incidents,
are not representative and cannot properly be used to estimate national occurrence.
In addition samples collected by States in response to contamination incidents are
frequently not subject to riqorous QA/QC standards, so that we are not confident
in the accuracy of the results. Although ODW does not have the authority to mandate
specific QA/QC requirements, we may be able to use state-generated data in the
future. Through our laboratory certification program we are working with the States
to increase their sensitivity to the need for proper QA/QC procedures, thereby
increasing the quality of the data. It should be noted, however, that data arising
from the investigation of specific contamination incidents, even if collected in
conformance with proper QA/QC procedures, are not statistically representative of
conditions in general and therefore of very limited use in helping us to understand
the nature and extent of contamination nation-wide. Despite these limitations,
State activities can be invaluable in alerting EPA to new and emerging problems, which
we learn about through our informal contacts with State health and water quality
authorities. Moreover, the results of some large State surveys, such as those
conducted by New York and California, may be adequate for inclusion in the data
base we have built from our own surveys. We will explore the appropriateness of
incorporting such data as they become available.
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As an example of the way in which monitoring activities support standard
setting, consider the following revisions to the current standards. The Phase I
revision to the National Interim Primary Drinking Water Regulations addresses the
volatile synthetic organic chemicals most commonly found in drinking water. The
nine specific chemicals we selected for possible control were determined with the
assistance of statistical occurrence models which made use of combined data from
several organics monitoring surveys we have conducted over the years. The Phase
II and III revisions (see Appendix C) and future changes will be supported by the
National Inorganics and Radionuclides Survey (NIPS) and by the National Pesticides
Survey. These surveys are discussed on pages 5 and 6.
The contaminants we consider include inorganic and organic chemicals, radio-
nuclides and microorganisms. The consideration of contaminants in drinking water
for which standards may be needed is complicated enormously by their wide range of
physical, chemical, and physiological properties.
Experience has shown that the design of surveys to gather occurrence data must be
related to the nature and extent of the contamination problem. For example,
chemical contaminants or radionuclides in ground-water sources, confined to limited
local or regional areas, present a problem very different from chemical contamination
of surface waters observed nearly nationwide. Contaminants introduced in treatment
or distribution of drinking water present still another set of considerations. In
addition, the size of the system, which usually is related to its technical capa-
bilities and to its funding resources, is a factor that must be considered in both
monitoring and treatment aspects of standard setting. To ensure the accuracy of
the analyses of water samples, we require that they be performed in ORD or certified
laboratories.
B. Extent to Which Needs are Being Met; Monitoring Plans.
Several surveys, of differing scope and with a wide range of goals, have been
supported by QDW over recent years,2/ while other surveys, now in the planning
stage, will support our regulatory activities in the future. These surveys reflect,
in their increasing breadth and complexity, the increase in our ability to identify
National Organics Reconnaissance Survey; National Organics Monitoring Survey;
SRI-Pesticides Survey; Rural Water Survey; Community Water Supply Surveys (2);
National Screening Program for Organics in Drinking Water; Ground Water Supplies
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pertinent variables, to involve a greater number of experienced analysts, to provide
more comprehensive planning, to provide greater quality assurance support and to
respond to more complex and sophisticated technical and management questions.
ODW's monitoring plans are determined by our plans for the development of
drinking water regulations, which are divided into four phases (See Appendix C).
Occurrence data in support of Phase I, volatile organic compounds, is provided by
the GroundWater Systems Survey conducted in 1981-82. Occurrence data for that
part of Phase II which deals with revision of currently regulated contaminants has
been obtained from the monitoring conducted by the public water systems pursuant
to the regulations, supplemented by other available data. Phase II will also
cover, to the extent possible, additional contaminants not currently regulated,
particularly pesticides which have been found in ground water, such as DBCP, EDB,
and Aldicarb. The urgency of regulating these contaminants will require us to use
existing data on their occurrence, even though they are not as complete and systematic
as we would like. Occurrence data for Phase III, radionuclides, will be provided
by the National Inorganics and Radionuclides Survey described below. Finally, it
is still too early to define data requirements for Phase IV, disinfection by-products.
In addition to these efforts tied to our current plans for regulation development,
we have efforts underway to seek out new and emerging problems. The National Inorganics
and Radionuclides Survey will cover a wide range of unregulated inorganic contaminants,
in addition to a number of inorganics and radionuclides which we plan to regulate in
Phase III. The National Pesticides Survey will come too late for Phase II, but it
will provide a systematic data base on drinking water contamination with pesticides
for use in future standard-setting activities. This is a major effort which
is expected to require $500,000 - $1 million in resources over its two-year duration.
Finally, our continuing technical assistance activities with the States for contami-
nation incidents provides an early warning system for contaminants not currently
on our agenda which may become a source of concern in the future.
National Inorganics and Radionuclides Survey
The National Inorganics and Radionuclides Survey is a major surveillance
mechanism being supported by ODW to provide current occurrence data upon which
standard setting for revised regulations will be based. This survey aims to provide
"quality assured" occurrence information focusing on a large number of inorganic
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contaminants, some of which are now included in the interim regulations/ and on
several radionuclide measurements. For many of these, no systematic data on
occurrence is now available. Included in this planning is an effort to define
necessary data accumulation, data manipulation and data transmission techniques to
assure a body of information useful for scientific conclusions and for support of
environmental policy decisions. The occurrence data obtained in NIRS will be
evaluated and summarized for these purposes. Then, projection of these findings
will allow an approximate determination of the national impact of proposed regula-
tions. The NIRS study began in the Summer of 1984. (See Appendix A for a list of
constituents to be evaluated).
National Pesticides Survey
The need for current, scientifically valid pesticides occurrence data to
support any future standard setting has been recognized. Recent findings of
regionally widespread ground-water contamination by halogenated organic chemicals
injected into the soil (one type of pesticide) have added impetus to the need for
a broad survey of pesticide contamination. The spectrum of pesticidal chemicals
reported present in drinking water over the past ten years provides one example of
the complexities involved in planning and implementing a national survey. Pesticides
vary greatly in chemical, physical and biochemical properties. Therefore, measure-
ment of these chemicals in water is difficult and toxicological considerations are
complex.
C. Data Handling
Particular emphasis will be placed upon the storage of data obtained from future
surveys. The data obtained from NIRS and future surveys, including pesticides, will
be accurately entered into a computerized data base, and ODW will rely on a SAS file
for analytical capability. We are also considering placing all of the other sample
data collected by ODW into the same data base. The other sample data includes
anecdotal data collected through special sampling support, response to incidents of
ground-water contamination, and similar types of information collection activities.
D. Quality Assurance Aspects of Surveillance and Monitoring for Standard Setting
ODW has improved the quality assurance support for its surveillance and moni-
toring efforts markedly as experience with surveys has increased. Particularly
since the Ground-Water Supply Survey was carried out, major concern has been
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demonstrated for improving data quality and for the documentation of data quality.
To make the presently planned NIRS a more useful source of occurrence data, much
effort is going into consideration of data quality indicators.
An aspect of quality assurance support receiving increased emphasis is data
storage, data reduction or manipulation, data retrieval procedures and data sharing.
Sharing of occurrence data between EPA programs adds emphasis to the need for our
being able to evaluate the quality of our collected contaminant occurrence data.
E. Linkages with other Programs
The Office of Drinking Water maintains formal and informal ties to other
programs in EPA. We are members of ORD's Water Research Committee, which provides
a forum for discussion of research needs on health effects; contaminant measurement
technology, and the identification and tracking of underground plumes, among others.
OEW and OPP have established a formal work group which will address the sample design
of the Pesticides Survey, as well as other matters, such as drawing and analyzing
the samples. The coordination between the two offices has been formalized in a
Memorandum of Understanding signed by the Office Directors. Although this group
cannot possibly reconcile the inherent differences in ODW's schedule for promulgation
of pesticides regulations with the lengthy time period required to properly design
a survey as complex as the Pesticides Survey, the work group will nevertheless
play an invaluable role in helping ODW gather and analyze existing data and in
detecting new problems of drinking water contamination by pesticides.
III. EVALUATION OF SYSTEM COMPLIANCE WITH DRINKING WATER STANDARDS
A. Goals and Objectives
The goal of this program is to provide data and information on the extent to
which systems are meeting the requirements of the Safe Drinking Water Act. As part
of the Public Water System Program, EPA develops standards, called Maximum Contami-
nant Levels (MCL's), for contaminants which may have an adverse effect on health.
(See Appendix B). Should a State show that it has standards and enforcement
authorities that are at least as stringent as those promulgated by EPA, primary
enforcement responsibility ("primacy") may be delegated to the State. The State
then accepts day-to-day responsibility for assuring that monitoring is conducted,
that standards are met, that systems which do not meet the various requirements
-------
are brought into compliance and that they will complete a number of other manage-
ment and reporting tasks. We ensure the accuracy of the analyses of samples
collected during routine monitoring by specifying acceptable analytical methods.
At this time, 52 of the 57 States and territories have been delegated primacy; EPA
Regional Offices are responsible for program operation in the remaining 5 States.
One of the reports which primacy agents must give to EPA involves the compli-
ance status oE regulated systems. The primacy agents submit an "exceptions report"
which contains a listing of violations of the drinking water standards and the
actions taken by the primacy agents in response to the violations. Also included
in the report is the inventory of the regulated public water systems.
The information received from the States and regions which implement the Public
Water System Program (primacy agents) is used in a number of ways. The inventory
information indicates the relative number of systems (and workload) under the control
of the primacy agent and is used as a weighting factor in the calculation of State
program grants. The information on violations are used to identify problems within
primacy agent programs, e.g., high violation rates in certain categories of systems
or violations of certain parts of the standards, and as a tool for managing the
program. If violation rates indicate problems in certain geographical areas, staff
time can be reallocated to increase contact with the suppliers and increase compli-
ance rates. Follow-up and enforcement actions are reviewed to determine whether
the primacy agent is acting appropriately in response to violations.
At least annually the primacy agents submits the information on violations and
follow-up actions, to EPA. We then aggregate it to national totals and prepare an
annual compliance report which is used by OEW to track trends in compliance and to
identify problem areas. The report graphically displays the compliance status of
the Nation's public water systems. It is made available to Congressional staffs,
OMB, the Regions and States, and industry and environmental groups. If desired,
this information can also be aggregated by region, population served, etc., for
different analytical purposes.
B. Quality assurance/quality control.
A number of efforts have been undertaken to assure that the quality of analytical
data and reports based on the data are accurate and representative of actual water
quality for both regulated and unregulated contaminants. In FY 81, the Office of
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-9-
Drinking Water began a data verification effort by visting primacy agent offices
and reviewing reports received from water suppliers and comparing them to reports,
theoretically based on the same information, which were submitted to EPA. Results
ot the study indicated that there were inconsistent definitions of violations
wthin various State programs, that many violations which occurred were not reported
to EPA, and that there were management shortcomings which could impede the correction
of the first two problems areas. ODW has published a formal guidance document
presenting a methodology for verifying data in a primacy agent's offices, and to
date, approximately 30 primacy agents' programs have been reviewed. The reviews
have resulted in clarification of rules for determining violations and changes in
internal operating procedures to strengthen control over compliance information.
They have also led to a growing recognition that, if compliance data are to be used
as a management tool, their validity must be beyond doubt.
The National Interim Primary Drinking Water Regulations require that analyses
for the various regulated contaminants be performed in certified laboratories. In
1978, ODW published an interim manual on certification of laboratories for drinking
water analyses. This manual was updated in 1982 and provides information on the
types of equipment needed to perform analyses, procedures for assuring that analyti-
cal techniques are correct and repeatable and information on management items such
as chain-of-custody and documentation of quality assurance plans. As a means of
ensuring that a high level of quality is maintained, a performance evaluation
program is conducted in the certified labs. Under this program, at least once a
year prepared water samples containing known types and amounts of contaminants are
submitted for analysis to the laboratory. The laboratory is not informed of the
nature or concentration of the contaminants until the analysis has been completed.
The laboratory's analysis is compared with the known composition and departures in
the analysis from the actual content of the samples are discussed with the labora-
tories, and corrective steps taken. If necessary, a laboratory can be decertified.
Technical assistance in the form of training in correct analytical procedures,
research into improvements of analytical methods and use of automated data manage-
ment systems to manage data also help to standardize data quality. We also train
state managers on how to use the data to improve their own programs, thereby giving
them an incentive to take a continued interest in the generation of reliable data.
As discussed under Generalized Technical Assistance, these activities vary from
informally providing expert advice to formal, structured training seminars. The
cumulative efforts in data verification, laboratory quality assurance and technical
and managerial asistance have tended to normalize program operations to the extent
necessary for the programs to generate consistent, replicable data and reports.
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C. Extent to Which Data Needs are Being Met.
We have good overall data on compliance rates and can analyze them in consi-
derable detail. This enables us to accurately measure the effectiveness of the
program in improving the quality of drinking water.£/ Notwithstanding the high
quality of the data, experience with the program has suggested that certain improve-
ments will increase efficiency and reduce the burden on the reporting entities.
At this time, we are discussing several specific improvements with the states and
are moving toward implementation, e.g.,
0 submitting compliance and enforcement information quarterly
(presently it is submitted annually approximately 6-18 months
after collection)
0 reporting more detailed information on violations, and follow-up
0 the use of a new list of standard definitions of enforcement
actions to be used in follow-up reports of non-compliance.
The change in reporting frequency is being considered in order to be consistent
with Agency efforts to obtain enforcement data on a quarterly basis, and as a
means of improving compliance.
D. Data Analysis.
The information collected from the primacy agents on violations types,
frequency and duration of violations, population served, etc., are used, in con-
junction with the priorities established in the primacy agents' compliance strategies,
to identify systems which need attention, and to develop suitable responses, ranging
from technical assistance to enforcement, to bring them into compliance. We set
numerical goals for compliance and track non-compliance from year-to-year to see
if the situation is improving. (These goals are increased over time). Compliance
data are provided to Congress and are used in the review of existing standards,
along with other data. As a companion to the development of the strategies, EPA
has standarized definitions of violators based on length of violation. For bacteria
Improvements in monitoring have historically resulted in a short-term
increase in violations. Over time, as remedial action occurs, the rate
of violations should decrease.
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and turbidity, which are monitored on a monthly or quarterly basis, a persistent
violator is one who violates the standards four or more months, while an intermittent
violator is one who is in violation three or fewer months or one quarter. For all
other contaminants, any other MCL violation will be considered a persistent viola-
tion. The automated data management systems in use by EPA (the Federal Reporting
Data System-FRDS) and some primacy agents (the Model State Information System -
MSIS) allow for violators to be sorted in some priority order to facilitate their
review and ranking against the compliance strategy's priorities.
MSIS was developed by EPA for use by primacy agents to handle the day-to-day
manipulation of compliance information. Analytical results are loaded into the
system, which will then determine whether the water system violated any of the
standards and will record actions taken in response to the violations. This infor-
mation is then converted to the format necessary for FRDS, the national system.
FRDS stores the monitoring and violation information from all primacy agents, and
is used to prepare reports comparing National, Regional and State compliance.
Reports are compared from year to year as FRDS has been receiving data since FY
78.
Information entered into FRDS is publicly available. On a regular basis,
ODW provides information to Congress, environmental groups, interested citizens,
and other private and public agencies.
Two major changes are being made to FRDS. First, FRDS data is being linked
to Superfund's National Priority List. Subsequently, linkage will be made to
other environmental data. Second, FRDS is undergoing major revisions designed to
improve its capabilities for support of the management decision process. This will
include an ability to store sample data (e.g., from special studies or surveys) and
information of interest solely to the states.
EPA is initiating the development of a data system using state-of-the-art
microcomputer technology which will allow a state to distribute computational/data
management assistance to state administrative offices. This new capability will
provide the basic data management requirements while at the same time provide for
the addition of primacy agent specific information. Like MSIS, this new capability
will convert information to a format acceptable to FRDS.
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IV. CONTAMINATION INCIDENTS
A. Opals and Objectives.
The goal of this activity is to conduct special studies and to provide expert
technical assistance when incidents of contamination of drinking water supplies
occur. Ordinarily, State and local governments (frequently supported by EPA grant
funds) are the primary agencies to deal with such cases. The Regional Offices are
involved directly in non-primacy States and in a technical assistance node in
primacy States. In addition, the Regional Drinking Water programs frequently
assist their counterparts in the Hazardous Waste and Superfund programs, especially
when public water systems have been contaminated. Headquarters also participates
on a case-by-case basis in such activities.
When contamination is discovered, monitoring is conducted to accurately define
the scope and magnitude of the contamination, to identify the source(s) of contamination
and to provide an assessment of the future potential expansion, movement, and control
of the contamination plume. The monitoring is generally conducted by the State, if it
has been granted primacy authority for administering the drinking water regulations,
or by the EPA regional office, if the state has not been delegated authority for the
program. In addition, guidance V and technical assistance is provided by headquarters
which may take many forms, such as:
0 issuing Health Advisories to Regional, state, and local officials
specifying, in the absence of standards, suggested acute and chronic
contaminant concentrations, above which a potential health hazard
may exist
0 providing information on the availability and use of suitable sampling
and analytical methods
£/ ODW and OPP are currently working on procedures for the joint development of
health advisories for those incidents where the contaminant is a pesticide.
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0 providing information on the availability of suitable treatment
technologies for contaminant removal, and
0 providing cost estimates for monitoring and treatment of other means
of control.
Health advisories are prepared after receiving an informal request from the
local authority having jurisdiction over drinking water quality. They are based
on thorough research which considers toxicity research being done in EPA and else-
where, as well as the opinion of recognized professionals outside the Agency.
Health advisories also briefly address analytical methods and available treatment
technologies.
B. Extent to Which Needs Are Being Met.
A number of problems exist in the above described approach to respond to
contamination incidents. First, since standards do not exist for most contaminants
for which there is an emergency, such as ethylene dibromide (EEB), non-uniform
application of Health Advisories and guidances occurs, and the potential exists for
the various offices and regions to give different guidance. Action levels for the
same contaminants frequently vary from one state to another. Levels of concern
also vary between states, which translates into non-uniform and often inconsistent
monitoring approaches, and thereby inconsistent and inadequate problem definition
and resolution.
Second, due to the short time required to respond to an emergency, inadequate
attention is often paid to quality assurance (QA). Exacerbating this problem is
the inconsistent application of QA measures between regions and states, leading to
the generation of data which cannot be compared.
Third, inadequate analytical methodology often exists. To illustrate, for
the case of EEB, the methodology to measure this chemical at 20 ng/L exists but it
requires skilled analysts and state-of-the-art analytical instrumentation. Few
laboratories had the capability when the crisis arose. As a consequence, data
were generated which were suspect, and significant lead time was required to
characterize laboratory capability to measure EDB and to suggest alternative
procedures. Development of these capabilities is still underway.
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Fourth, monitoring data which are generated are stored at the state and local
level, and cannot be easily accessed because they are not centralized. In addition,
there are no uniform approaches to documentation of the data, description of the
method of collection, and quality assurance.
C. Plan to Meet These Needs.
In the future, standards will be promulgated in Revised Drinking Water Regula-
tions for many of the contaminants which have been shown to have national or regional
health implications. (See Appendix C). Recognition of them as health hazards
often occurred in response to contamination incidents. When these standards are
set, compliance monitoring regimes and data reporting will be specified in the
regulations along with analytical methodologies, treatment technologies, and other
requirements. For these contaminants, many problems will be resolved in that
uniform information will be applied and data will be gathered under prescribed
conditions.
However, there will inevitably be incidents in the future involving contaminants
which are not regulated, as a result of Superfund site assessments, monitoring around
existing hazardous waste sites, monitoring of drinking water sources and monitoring
in connection with agricultural uses of pesticides. Emphasis should be placed on
dealing with and resolving the problem areas noted above, namely, potential incon-
sistency in health advisories and monitoring approaches; inadequate attention paid
to QA, and inadequate analytical methodology. A preferred manner is to work with
Regional, state, and local programs to develop common mechanisms to deal with
monitoring data, to locate contaminated ground water, to increase their awareness
of the need for careful QA measures, and to protect the health of people whose
source of drinking water may be impacted by identified contamination.
EPA has no current plans to gather together the data collected by States and
public water systems in connection with contamination incidents or to place it in
a single data base. Previous attempts to use such data, particularly in connection
with regulations for volatile organic chemicals, have had limited success, in part
because the data have not been well documented as to quality or circumstances of
collection. Even if these are improved over time, however, the data will still not
be representative, since it will reflect locations known or suspected to be contami-
nated. It will, therefore, not be possible to use it to project national distri-
butions of contaminant levels.
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The data are still valuable, however, In two ways. First, it is part of a
process of responding to drinking water contamination that leads to cleaner water
and reduced human exposure to contaminants. The drinking water program has found
that this informal and nonregulatory process has been extremely successful in
protecting the public health. Second, as mentioned earlier, it forms part of
EPA's (and the drinking water profession's, generally) early warning system for
emerging problems. Many of the contaminants for which regulations are currently
under development first came to our attention as contamination incidents, at first
isolated and then with increasing frequency, until it became clear that formal
regulations were warranted.
V. UNDERGROUND INJECTION CONTROL PROGRAM
A. Goals and Objectives.
The Underground Injection Control program is a Federal/State Program designed
to control the subsurface emplacement of fluids by well injection in a way which
will prevent the endangerment of underground sources of drinking water. The program
was established by the SDWA of 1974 and provides for authorization of well injection
by either permit or rule. Persons operating injection wells under either scheme are
required by regulation to conduct certain monitoring and report the results to either
the State or EPA.
Injection wells have been segregated in the regulations into five classes, as
follows:
Class I: Hazardous waste and other industrial or municipal
wells injecting below the deepest underground source
of drinking water (USDW)
Class II: Injection wells associated with oil and gas production
or storage,
Class III: Mineral extraction wells
Class IV: Hazardous waste or radioactive waste disposal wells
injecting into or above a USDW
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The regulations require operational monitoring, monitoring of the wells'
physical condition, and ground water monitoring. Operational monitoring require-
ments include such parameters as the nature of the fluid being injected; injection
pressure; injection flow-rate, and volume injected. Monitoring of the physical
condition of the well includes tests to determine the integrity of the tubular
goods and of the cement sealing the annulus between the tubular goods and the
borehole. Ground water monitoring involves the monitoring of the ambient quality
of underground sources of drinking water. Class IV operators are required to
close their wells and cease operation in six months, so no general reporting require-
ments are included. Class V is so diverse that reporting is at the discretion of
the Director.
B. Quality Assurance.
The UIC program is, of course, subject to the Agency's QA policy, but the
types of monitoring it requires do not fit the conventional QA model.
To develop a quality assurance plan for the UIC program, OEW has divided the
required monitoring into three categories:
0 Water quality measurements. This includes measurements of water
quality parameters such as those addressed in the NPDES program
and EWS program; QA requirements for these are generally available.
0 Physical measurements. This includes the physical measurements
normally associated with volumes, rates and pressures.
0 Geophysical measurements. This includes measurements such as
radioactive tracer surveys and electric logs.
By far the most important of the measurements in the scheme of the UIC regula-
tions relate to physical and geophysical parameters, not to water quality, since the
technical parts of the regulations largely deal with the physical integrity of the
well and the movement of fluids away from the vicinity of the injection well and
into underground sources of drinking water.
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We are working on a quality assurance program in cooperation with the Regional
Offices, States and the Office of Monitoring Systems and Quality Assurance and
Monitoring. Under this effort we are planning to examine the feasibility of developing
standard operating procedures (SOP's) and other guidance on how to perform the
required physical tests and other activities. We are also planning to develop SOPs
for the required mechanical intergrity tests and to develop a manual describing
these procedures.
C. Extent to Which Needs Are Being Met.
This section will of necessity, be brief, for the implementation of the UIC
program has only recently begun. We will begin conducting audits of selected State
programs later this year, and the information obtained will enable us to evaluate
the States data management procedures, among other things.
To date we have negotiated with and obtained the agreement of the States on the
reporting of summary data. This will be done in two categories: administrative
measures and environmental measures. Administrative measures relate to things like
the number of permits issued, and environmental results measures relate to the number
of mechanical integrity tests performed; the number of violations, and remedial
action; failure rates of mechanical integrity tests; remedial action in the area of
review, etc. As we gain more experience with the program and build a data base, we
will be in a better position to determine the extent to which current monitoring
activities fulfill our data needs.
VI. OTHER MONITORING ACTIVITIES
EPA is frequently asked to provide monitoring assistance or to conduct studies
dealing with various issues. Although related to drinking water quality they do not
readily lend themselves to the categorization scheme above. Therefore, we have
grouped them into this "other" category. It should not be concluded, however, that
an activity appearing in this section is insignificant. Despite their difficulty in
categorization, they can be significant in terms of their resource requirements,
such as the new Surface Impoundment Assessment we were directed to perform by the
Administrator, or significant in terms of the inportance of the assistance we
provided, notwithstanding the relatively modest resources expended, e.g., as that
provided under general technical assistance.
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A. General Technical Assistance
The objective of this activity is to support the drinking water effort by
providing assistance in a variety of ways. The common thread for all these activities
is to permit Regional, state, and utility programs to characterize, in a coordinated
way, their water supplies so that expertise can be gained to independently conduct
monitoring exercises. Examples of activities include:
0 Assisting Regions and states in conducting carefully planned studies,
with appropriate quality assurance incorporated, to characterize chemical
contamination. This has ranged from managing laboratory analyses
performed by a contractor to providing information on how to conduct
these measurements. With this assistance, several Regions and states have
been able to examine in detail the frequency of occurrence and magnitude
of volatile organic chemical (VOC) contamination in surface and ground
water supplies. In several cases, discovery of WC contamination has
triggered a response to a contamination incident.
0 Working with Regions, states and utilities in conducting compliance
monitoring activities. In several cases, technical difficulties caused
uncertainty in the validity of compliance data. Review of these data,
along with occasional laboratory analyses, has assisted in resolving
these difficulties.
0 Providing information on how to conduct monitoring. Frequently, a
paucity of technical expertise exists. This has been mitigated by:
offering guidance on contaminant measurment methods,
explaining existing monitoring requirements and suggesting
monitoring approaches and strategies where none exist,
providing on-site assistance in contaminant measurement procedures
(such asssistance has been extended to the States of Arizona and
Hawaii and the Commonwealth of Puerto Rico), and
- developing and presenting seminar programs on trihalomethane
measurement and monitoring at national American Water Works
Association meetings.
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B. Monitoring by Regional Laboratories
Monitoring activities on an EPA Regional level are planned by the Regional
drinking water program in consultation with the states, water systems, and
Headquarters. The drinking water program within each Region assigns a number of
positions to the Environmental Services Division (ESD) to plan and conduct sampling
and analytical efforts. The level of resources assigned to the ESDs and the tasks
they perform vary among the Regions. Also varying is the program's satisfaction with
the quality, and timeliness of the services performed. Irrespective of the assign-
ment of positions, three situations appear to exist:
0 Services provided are satisfactory, and ESD support is appropriate.
0 Services provided are satisfactory, but the resources assigned to
the ESDs are inadequate to perform the required monitoring tasks.
0 Unsatisfactory service is provided with little accountability of
ESD resources.
It appears that many of the nine regions having ESD laboratories fall into the
latter two categories. Herein lies a problem that needs attention. When insufficient
resources exist at the ESDs, Regional monitoring programs are not accomplished.
Grant or contract money is sometimes used to procure analytical resources which may
or may not satisfactorily accomplish monitoring objectives. ODW has sometimes
provided resources in these situations.
Where ESD resources provide little service, the Regional program must seek
assistance elsewhere. In doing so, duplicate human and financial resources are
expended. Again, ODW has provided assistance in some of these cases.
C. Monitoring in Support of the Sole Source Aquifer Program
The SSA program applies to areas where one aquifer is the principal source of
drinking water which, if contaminated, w^uld create a significant hazard to public
health. Once designated a sole source aquifer, no commitment of federal financial
assistance may be made for a project which may contaminate the aquifer through the
recharge zone. In order to effectively manage the program, monitoring of ground-
water quality is conducted, the nature of which depends on the ground-water quality
problems faced. For example, in the Whidbey Island Aquifer, purgi'ole volatile
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organic chemicals emanating from a military installation are tracked, and in the
Spokane-Rathdrum-Prairie Aquifer, nitrate and nitrogen levels are monitored. A
memorandum of understanding between the EPA Regional Office and the Federal Housing
Administration (FHA) provides that if nitrate or nitrogen levels exceed certain
levels, FHA-insured home loans will not be made. The monitoring is generally con-
ducted by other Federal Agencies as part of the NEPA process, with limited direct
participation by EPA.
D. The Surface Impoundment Assessment
The original SIA was intended to provide a first approximation of the contamina-
tion potential of surface impoundments - pits, ponds and lagoons used for waste
treatment, storage or dispoal by industry and municipalities. This study revealed
that there are more than 180,000 impoundments, almost half of which are located
over thin or permeable unsaturated zones which are vulnerable to contamination.
Most of these impoundments are unlined, and about one-third of the industrial sites
\
contain wastes which may be hazardous. At the direction of the Administrator, we
are now designing a follow-on SIA which will include ground-water monitoring, which
the original survey was not designed to do. It will cover impoundments not covered
by the Hazardous Waste program (those that do contain hazardous wastes are required
to monitor under the hazardous waste regulations). In view of the expense of
drilling ground water monitoring wells, it is likely that monitoring will be conducted
at selected sites where monitoring or drinking water wells already exist.
E. The Rural Water Survey
The Rural Water Survey, mandated by Congress, focussed on individual and small
cluster systems serving rural areas. It was intended to shed light on matters such
as the number of rural residents inadequately served by a public or private water
system; the number exposed to health risks due to inadequate supplies, and the number
which actually contracted illnesses which could be attributed to such supplies. The
survey, which provides the first comprehensive, statistically valid picture of rural
water systems, showed, among other things, that approximately twenty five percent of
the surveyed households exhibited some evidence of bacterial contamination. It also
confirmed the widely held view that contamination rates were lowest in public water
supplies and highest in individual systems not meeting current construction standards,
e.g., cisterns and dug wells. Properly constructed wells had lower rates of contami-
nation in their water supplies than improperly constructed ones, but higher rates
than public water systems.
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VII. DRINKING WATER PROGRAM - MONITORING INITIATIVE RESOURCES
A. INTRODUCTION
This discussion of resource requirements is divided into two basic parts.
First, there appears a discussion of FY 85 requirements according to two
definitions of monitoring. The expanded, or broad, definition encompasses
all those activities identified in the Deputy Administrator's December monitoring
policy memo, namely: planning the collection of environmental data to meet
specific program objectives and environmental information needs? designing
monitoring systems and studies; selecting sampling sites; collecting and
handling samples; lab analysis; reporting and storing the data; assuring the
quality of the data; and analyzing interpreting, and making the data available
for use in decision making and reporting to the public. The narrow view of
monitoring relates to activities beyond the planning and design stage, i.e,
the actual collection and analysis of samples, and everything related to data
interpretation, storage, retrieval and dissimination. In terms of the
structure appearing in the policy memo, the narrow view enconpases reporting
and storing the data; assuring the quality of the data; and analyzing,
interpreting, and making the data available for use in decision making and
reporting to the public.
Under the expanded definition there is contained in the FY 85 budget a
request for 148 full time equivalent (FTE) positions and $9.8'million. For
activities under the narrow definition, the FY 85 budget request would be
for 78 FTE's and virtually the same dollar amount. The reason the amount
requested does not differ materially betwen the two definitions of monitoring,
despite the significant difference in FTE's, is that there is no difference
in the component, financial assistance to State programs; it is $9.5 million
under both views of monitoring activities.
The second basic part deals with additional activities which could be
pursued in FY 1986. They cover a broad range from the conduct of several
major occurrence surveys, to the assessment of certain technical requirements
in the UIC regulations. For FY 86, the budget could be increased by
approximately 43 FTE's, and between $5.8 and $15.3 million.
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B. CURRENT LEVEL OF EFFORT; FY 1985 BUDGET REQUEST
EXPANDED DEFINITION OF MONITORING FTE EX $000
1. D.W. HQs (63C2B) 36.5 250
0 Support for NPDWR Development - 17.5 200
exposure assessment; evaluation of
analytic methods for establishing
monitoring requirements.
0 Evaluation of PWS Compliance - 8.0
assembly and analysis of National
compliance profile from annual
exceptions reports (include ADP
systems development and maintenance;
continuing data verification; Lab
certification and QA projects
oversight.
0 Response to Contamination Incidents
and General Technical Assistance 5/ 6.0 50
assist in the identification and
interpretation of potential health
risk posed by incidents of contamination
in drinking water sources with special
analytic services and advice on treat-
ment; interpret the estimated health
risk posed by levels of contamination
detected via analyses.
0 Evaluation of UIC Compliance (including 5.0
Sole Source Aquifer and Surface Impoundment
Assessment - assembly and analysis of
nationwide UIC monitoring data (administra-
tive and environmental measures), including
development of ADP systems; administration
of QA program for water quality, physical
and geophysical measurements.
V Does not include resources for Health Advisory development.
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2. REGIONAL PWS PROGRAMS (70C2D) 66
° Evaluation of PWS Compliance (in areas 20.6
under EPA jurisdiction);
- PWS Surveillance - operation and (8.5)
maintenance of data system; inventory,
operator monitoring, data entry and
retrieval.
- On-site inspections of MCL violators (4.1)
(include sampling).
- Emergency Response (investigations of (2.5)
unregulated contamination occurrence)
and Disease Surveillance.
- Eton-Community Systems Surveillance (5.5)
° Evaluation of FWS Conpliance (in Primacy 24.9
States) - assembly and analysis of States'
compliance data.
0 Response to Contamination Incidents - 10
assist in the identification and
interpretation of potential health
risk posed by incidents of contamination
in drinking water sources.
0 Laboratory Analysis supporting lab 10.5
certification and site inspection sampling
3. REGIONAL UIC PROGRAMS (71C2D) 45.8
° Evaluation of UIC Compliance (in areas 40.4
under EPA jurisdiction)
- Injection Surveillance - making physical, (37.6)
geophysical and/or chemical measurements
of wells operating under permit or rule
- Data Management and Inventory Tracking (2.8)
° Evaluation of UIC Compliance (in primacy 5.4
States) - assembly and analysis of states'
compliance data.
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4. FINANCIAL ASSISTANCE TO STATE PROGRAMS (65C2C & 66C2C)
0 Evaluation of PWS Compliance - Funds 7,246.8
applied by states to support: laboratory
capability, lab. certification, disease
surveillance and sampling (accompanying
sanitary surveys) (est) 6/
0 Evaluation of UIC Conpliance - Funds 2,309.4
applied by States to support UIC well
monitoring, surveillance, mechanical
integrity testing and data management
activities (est) 7/
PROGRAM TOTAL 148.3 9,806.2
6_/ Estimate based on States' reports of planned expenditures (FY 1983 Grant)
7/ Estimate based on UIC State Model.
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LIMITED VIEW OP MONITORING
FTE Ex $000
1. HQs (63C2B) 18.5 200
0 Support for NPDWR Development - Sampling, 7.5 150
analysis and contractual support for
exposure assessment.
0 Evaluation of PWS Compliance - Program 3.0
development and oversight of Laboratory
Certification and QA.
0 Response to Contamination Incidents 6.0 50
and General Technical Assistance -
Analytic support for the identificat ion
and interpretation of potential health
risk posed by contamination incidences-
referred by State and Local authorities.
0 Evaluation of UIC compliance - Administration 2.0
of QA program for water quality, physical and
geophysical measurements.
2. REGIONAL PWS PROGRAMS (70C2D) 39.3
of PWS Compliance (in areas 18.5
under EPA jurisdictionT;
- PWS Surveillance - inventory, operator (8.5)
monitoring data entry and retrieval.
- Water quality sampling related to (2.0)
inspection of MCL violators.
- Emergency Response (investigations of (2.5)
unregulated contamination outbreaks)
and disease surveillance.
- Non-Community Systems Surveillance - (5.5)
inventory, monitoring data; sampling
for MCL violators.
° Evaluation of PWS Compliance (in Primacy 8.3
States) - Assembly and analysis of states'
compliance data.
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0 Response to Contamination Incidents - 2.0
guidance and technical support to
monitoring plans for the identification
and interpretation of potential health
risks.
0 Laboratory analysis supporting Laboratory 10.5
Certification and site inspections.
3. REGIONAL UIC PROGRAMS (71C2D) 20.7
0 Evaluation of UIC Compliance (in areas 15.3
under EPA jurisdiction);
- Injection Surveillance - ground water (12.5)
monitoring, mechanical integrity testing
of wells operating under permit or-rule.
- Data Management and Inventory Tracking (2.8)
0 Evaluation of UIC Compliance (in primacy 5.4
states) - Assembly and analysis of states'
compliance data.
4. FINANCIAL ASSISTANCE TO STATE PROGRAMS (65C2C & 66C2C)
0 Evaluation of PWS Compliance - Funds 7,246.8
applied by states to support: laboratory
capability, lab. certification, disease
surveillance and sampling (accompanying
sanitary surveys), (est) 8/
0 Evaluation of UIC Compliance - Funds 2,309.4
applied by States to support UIC well
monitoring, surveillance, mechanical
integrity testing and data management
activities, (est) 9/
PROGRAM TOTAL 78.5 9,756.2
8/ Estimate based on States' reports of planned expenditures
(FY 1983 Grant).
2/ Estimate based on UIC State Model.
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C. ENHANCED LEVEL OF EFFORT; FY1986 BUDGET REQUEST
The following are possible projects to pursue as FY 1986 initiatives.
1. (HQ) National Reconnaisance Survey for Priority Pollutants in Drinking Water
HR 3200 would require EPA to promulgate NPDWR's for each of the 129
"priority pollutants" (12 of which now regulated as Interim MCL's)
unless the Agency found no basis to determine that a contaminant
wouldn't pose an adverse health effect. EVen if such a provision is
not enacted, its proposal and consideration signals Congressional
interest in widening the scope of national drinking water regulations
to encompass broad organic analyses of drinking water served by public
water systems. A national survey to establish the occurrence of
chemical pollutants in drinking water might satisfy Congressional
concerns, short of embarking on a massive new and unguided regulatory
initiative. EPA could pursue a rational regulatory strategy on the
basis of the survey. In the event such a provision is enacted, such
a survey will become imperative, to enable EPA to set appropriate
MCL's.
A national survey of this sort could serve two functions:
1) to define the risk posed by the toxic water pollutants now publicly
identified as waterborne concerns (under the priority pollutant
list), answering what seems to be a question in, the minds of the
public and Congress; and
2) to look beyond that list in targeting real drinking water
contamination problems (the proposal to regulate from the "gang of
129" is unusual not only because the list is too long, but also
because it skips many genuine drinking water contaminants, especially
pesticides, disinfection by-products and ground water contaminants).
Proposal - a nationwide occurrence survey would involve a large number
of samples (1000+ sites, 1 or more samples per site); fortunately,
available broad spectrum analyses may suffice, keeping per sample
analytic costs down. Resources would also be needed to provide guidance
in interpreting the health risk of contaminants uncovered, including
fast literature search and short-turnaround guidance for any "surprise"
compounds detected.
FY 1986 Resource Requirement (one year of a 2-year Survey):
FTE Intra $000 ESctra $000 (analytic support)
2-5 150 - 300 400 - 1,000
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2. (HQ) Pesticides Occurrence Survey
ODW is currently playing a major role in a joint ODW-OPP Survey to
estimate pesticide contamination in drinking water supplies. Given
the large number and variety of pesticide ingredients found in or
registered for use around drinking water sources (perhaps 50 or more
chemicals) this effort could easily be expanded.
A survey for pesticides poses particular technical challenges - the
required analytic techniques are far more elaborate and specialized
than for the priority pollutants, causing higher per sample analytic
costs.
Proposal - extensive occurrence survey (500+ sites) for selected
pesticides (up to 50 different contaminants); sampling and specific
analyses determined by prior analysis of use patterns.
FY 86 Resource Requirement (one year of a 2-year Survey)
FTE Intra $000 Extra $000 (analytic support)
0-3 100 - 200 150 - 500
3. (HQ) Assisting systems in "baseline" monitoring to establish compliance
for new contaminants under Revised NPDWR
Revised NPDWR promulgated in 1985 (for VOC's) and 1986 (for inorganics,
synthetic organic chemicals, (SOC's) and microbiological contaminants)
are likely to contain new MCL's and monitoring standards, requiring
systems to undergo at least one round of analyses to establish the
absence of contamination. To facilitate compliance with these new
requirements, EPA should be prepared to lend technical assistance
and analytic support.
FY 86 Resource Requirement
FTE Intra $000 Extra $000 (analytic support)
1-3 40-120 50 - 200
4. (HQ) National Occurrence of Intermediate molecular weight SOC's and
Disinfection By-Products
Survey would support Phase IV of the NPEWR Revision, commencing in FY
1986. Like the surveys for priority pollutants and pesticides, ODW
would have to be ready to help interpret the health risk of contaminants
uncovered by the survey. Analytic expenses per sample could be
exceptionally high for this, as much as $2,000 per sample.
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-29-
FY 86 Resource Requirement (1 year of 2 year Survey)
FIE Intra $000 Extra $000 (analytic support)
2-5 150 - 300 500 - 2,000
5. (HQ) Surface Impoundment Assessment
In FY 1985, ODW will begin conducting an assessment of surface
impoundments as a major unregulated source of ground water contamination.
While this effort is planned to involve some monitoring to help
characterize the contamination potential of impoundments, there
needs to be provision for additional monitoring to plot the contamination
in the event it's discovered, to guide remedial and management response.
FY 86 Resource Requirement
Extra $000
500 - 2,000
6. (Regions) Analytic support for the Issuance of Administrative Orders to
foster FWS & UIC Compliance
In the event EPA is granted authority to issue administrative orders
against non-complying PWS's and injection well operators, exercise of
that authority will entail sampling and analytic measurement. Regional
analytic capability will need to be increased correspondingly.
FY 86 Resource Requirement
PEE Intra $000
10 - 15 350 - 600
7. (Regions) Assisting the implementation of Revised NPEWR
FY 1986 will mark the implementation of new primary standards for
VDC's and the promulgation of revised standards for SOC's, inorganics
and microbiology. In all likelihood, regulations for any new
contaminants are going to include a provision that systems undergo at
least one round of baseline monitoring. Such monitoring will
undoubtedly be new and unfamiliar to a number of systems; they will
need help in establishing compliance with new MCL's. Moreover,
Regional laboratories will need to be enhanced to carry out their
responsibilities for laboratory certification and compliance
determinations in non-primacy jurisdictions.
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-30-
FY 86 Resource Requirement
FTE Intra $000
10 350 - 450
8. (PWS Grants) Disease Surveillance Enhancement
There is strong evidence that the number of waterborne disease
outbreaks are seriously undercounted because States have insufficient
resources to conduct a suitable surveillance system. In a R&D
demonstration program, states given resources to set up staff and a
notification system uncovered substantially more cases of disease, up
to 2 1/2 times more.
FY 86 Resource Requirement
Extra $m
1 - 3.75
9. (Regions) UIC Regulations Technical Review
UIC program regulations provide for EPA review of technical requirements
soon after their implementation to review their effectiveness and
burden. A key focus will be the provisions for regulating Class II
(oil & gas production) wells - EPA would like to test and monitor
injection wells that are a sample of the Class II population.
FY 86 Resource Requirement
FTE Intra $000 Extra $000
10 350 - 400 $500
10. (Regions) Sole Source Aquifer Protection Evaluation
In order to evaluate the contamination potential of Federally-assisted
projects certain amounts of ground water monitoring must be conducted.
In order to cope with the increase in applications for sole source
designations, it will be necessary to increase monitoring resources.
FY 86 Resource Requirement
FTE Intra $000 Extra $m
7.5 - 12 250 - 500 1.5 - 2.5
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RPP6NDIX fl:
Constituents evaluated in the National Inorganics
and Radionuclides Study
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-31-
APPENDIX A
Constituents Evaluated in the National Inorganics
and Radionuclides Study
Inorganics
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Zinc
Aluminum
Beryllium
Boron
Calcium
Cerium
Cobalt
Germanium
Lithium
Magnesium
Molybdenum
Phosphorus
RDtassium
Silica (SiO2>
Sodium
Strontium
Tellurium
Thallium
Thorium
Titanium
Tin
Uranium
Vanadium
Yttrium
Zirconium
Radionuclides
Gross alpha
Gross beta
Ra-226
Ra-228
Rn-222
Uranium
-------
nPP€NDIX B:
National Interim Primary Drinking ULJater Regulations
-------
-33-
APPENDIX B
NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS
Contaminant
Microbials
Coliforms
Turbidity
Radionuclides
Radium-226 + Radium-228
Gross Alpha particle activity
Beta particle and photon radioactivity
Inorganics
Arsenic
Barium
Cadmium
Chromium
Fluoride
Lead
Mercury
Nitrate (as N)
Selenium
Silver
Sodium and Corrosion
Organics
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP (Silvex)
Trihalomethanes
MCL (enforceable)*
<1/100 ml
1 TU (up to 5 TU)
5 pCi/1
15 pCi/1
4 MREM (annual dose equivalent!
0.05 mg/1
1.0 mg/1
0.010 mg/1
0.05 mg/1
1.4-2.4 mg/1 (ambient temp)
0.05 mg/1
0.002 mg/1
10 mg/1
0.01 mg/1
0.05 mg/1
No MCL, monitoring and
reporting only
0.0002 mg/1
0.004 mg/1
0.1 mg/1
0.0005 mg/1
0.1 mg/1
0.01 mg/1
0.10 mg/1
Monitoring and Reporting for each contaminant also required.
-------
flPP€NDIX C:
Future Standards
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-35-
REVISED PRIMARY DRINKING WATER REGULATIONS
The Revised Regulations will be developed in four phases:
Phase I: Includes regulations for the volatile synthetic organic chemicals
VOCs) which are most commonly detected in ground waters.
Phase II: Includes the development of regulations for other synthetic organic
chemicals (including pesticides), inorganic chemicals and microbiological
factors, plus reconsideration of the related interim standards.
Also, within Phase II, the fluoride regulations are being reviewed
on a separate track in response to a petition from the State of South
Carolina.
Phase III: Includes the development of regulations for radionuclides.
Phase IV: Includes the development of regulations for disinfection by-products
(including THMs).
The schedule is as follows:
Phase I Proposed RMCL June 1984
Proposed MCL December 1984
Final MCL September 1985
Phase II ANPRM October 1983
Proposed RMCL September 1984
Proposed MCL September 1985
Final MCL June 1986
Phase IIA Proposed RMCL Surgeon General Report Received;
Fluoride Scheduled being developed.
Phase III Proposed RMCL FY 85
Phase IV ANPRM FY 85
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-36-
PHASE I
MXs UNDER CONSIDERATION FOR REGULATION
Trichloroethylene Benzene
Tetrachloroethylene Para-dichlorobenzene
Carbon tetrachloride 1,1-Dichloroethylene
1,1,1-Trichloroethane
Vinyl chloride
1,2-Dichloroethane
PHASE II: INORGANICS, MICROBIOLOGICAL, OTHER ORGANICS
0 Phase II - Reconsideration of traditional standards (interim) and consideration
of additional contaminants for regulation.
0 All of the Interim Regulations are being re-evaluated, including comprehensive
review of the microbiological standards and associated monitoring requirements.
Micro standards under consideration:
Total Coliforms Viruses Legionella
Turbidity Giardia Surface Water Treatment Requirement
Inorganics - All under review, e.g., lead, nitrate, arsenic, barium, as well
as additional candidate, e.g., aluminum, asbestos, sodium, etc.
Synthetic organic chemicals under consideration: total of 44, including:
Aldicarb Ethylene Dibromide (EDB) Chlordane Xylene
DBCP Heptachlor Freons PCB's
0 Major Issues
- Small system compliance problems: How to deal with the economic capabilities
of small systems
- Monitoring requirements: How to relate minimum monitoring frequency with the
likelihood of detection of a problem
Costs of treatment vs. potential health benefits: HDW to quantify benefits
-------
-37-
PHASE II: FLUORIDE
In response to a petition from South Carolina, the fluoride MCL is being examined
on a separate track within the Phase II Revised Regulations.
In 1981, the State of South Carolina filed a petition requesting that EPA revoke
the fluoride regulation based on its contention that (1) fluoride in public water
supplies does not pose a health hazard, and (2) the costs of reducing fluoride
levels are prohibitively high and not justified by the benefits.
The Surgeon General responded to a request by EPA for a review of fluoride health
effects with a letter on July 30, 1982, stating
"ND sound evidence exists which shows that drinking water with the various
concentrations of fluoride found naturally in public water supplies in the
U.S. has any adverse effect on general health...[or] on dental health as
measured by loss of function and tooth mortality... to minimize the occurrence
of undersirable cosmetic effects, it is most prudent to maintain the upper
limit of fluoride in drinking water at two times the recommended optimum
concentrations".
The National Drinking Water Advisory Council (NDWAC) considered the fluoride
issue and recommended the following:
Fluoride should be added to the Secondary Regulations, designed to
prevent dental fluorosis effects.
An MCL for fluoride should be included in the Primary Regulations, designed
to prevent osteosclerosis (hardening of the bone). The MCL should be
somewhere in the range of 4 to 8 mg/1.
In response to a request by EPA to review the non-dental (medical) effects of
fluoride, the Surgeon General provided the following in a report received in
late January 1984:
- It is inadvisable for fluoride content in drinking water to be greater
than twice optimal for children up to age 9 to avoid dental fluorosis.
Fluoride concentrations should not exceed four times optimum to protect
against non-dental effects of fluoride in drinking water.
Additional research should be conducted on the relationship of excess fluoride
intake and skeletal maturation and growth in children.
A decision on the RMCL proposal is pending review of the Surgeon General's report
and briefing of Agency management.
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-38-
PHASE III: RADIONUCLIDES
A comprehensive reassessment of the Interim Regulations for radionuclides will
be conducted along with considering uranium and radon for inclusion in the
Revised Regulations.
Radionuclides under consideration include the following:
Gross Alpha Gross Beta
Radium-226 Uranium
Radium-228 Radon
A public workshop was conducted in May 1983 to discuss the technical and scientific
aspects of drinking water regulations for radionuclides.
A national survey of 1200 drinking water supplies will be conducted to determine
levels of radionuclides (and inorganics) in drinking water.
An ANPRM was published on October 5, 1983.
BMCL Proposal Scheduled for FY 1985.
PHASE IV: DISINFECTION BY-PRODUCTS
0 Revised Regulations will be developed for disinfectants and their by-products
including:
Reconsideration of the THM MCL,
Extending the THM regulations to systems serving less than 10,000 persons,
Addressing other disinfectants such as chlorine dioxide and ozone, and
Addressing other disinfectant by-products.
0 An ANPPM will be scheduled in FY 85.
-------
GROUND UUfiT€R
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JIN 14 m
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Draft Ground-Water Monitoring Issue Paper
FROM: Marian Mlay, Director 7/^v? *W-x,--
Office of Ground Water Protection . ,
u
TO: Headquarters Office Directors
Water Division Directors
Regions I - X
A draft ground-water monitoring issue paper is attached
for your review and comment.
As a part of the Agency's efforts to provide Monitoring
Strategies for all programs during FY 1985, the Office of
Ground Water Protection will develop an overall ground water
monitoring strategy. The draft issue paper is a first step
toward developing the monitoring strategy. The paper poses
several key issues:
- Should EPA establish explicit goals and objectives for
ground-water monitoring? If explicit monitoring goals
are established, what should the goals be?
- What should be the relationship between EPA and State
ground-water monitoring programs?
- Should EPA focus limited operational resources on
specific monitoring activities? Which activities
should be given greatest emphasis.
Preliminary recommendations concerning approaches to these
issues are offered in the paper as a starting point for
discussion. Also, a management framework and schedule for
developing of the ground water monitoring strategy are
described in the last section of the paper.
In reviewing of the issue paper, please consider the
following questions:
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- 2 -
- Does the paper pose the most significant ground water
monitoring issues? Are there additional major issues
which need to be addressed by the Agency prior to
initiating development of a more detailed monitoring
strategy?
- Is the description and analysis of alternatives appropriate?
We plan to rely on your comments to expand analysis
of alternatives and discussion of pros and cons of
various approaches.
- Do you have any recommendations for addressing these;
issues?
- How could we improve the strategy development process?
Please forward your written comments to this office by
Friday, July 13. Water Division Directors should provide
copies of the paper to other appropriate Regional Offices and
provide a single Regional Office response. In addition to
written comments, I would like to arrange small conference
calls with several Regions to discuss the issue paper during
the week of June 25.
At the Headquarters level, the issue paper will be an
item on the agenda of the first meeting of the Ground Water-
Steering Committee, made up of Office Directors implementing
ground-water related programs and several Water Division
Directors (to be selected). A meeting of the Steering
Committee will be scheduled for late June.
Please contact me (382-7077) if you have comments or
questions on the issue paper or review process.
Attachment
cc: Jack Ravan
Ron Brand
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GROUND-WATER MONITORING
ISSUE PAPER
I) Introduction
This paper identifies major issues to be addressed prior
to drafting of an Agency ground-water monitoring strategy.
Issues addressed in the paper include the appropriate goals
and objectives of a ground-water monitoring program, the
relationship of EPA and State monitoring activities, and the
EPA operational activities which should be given greatest
emphasis in a strategy. This paper also provides a description
of the process and schedule for developing the ground-water
monitoring strategy.
A) Background
In June of 1984, EPA will publish a final ground-water
Protection Strategy. The strategy calls for EPA to
assist State ground-water programs, deal with currently
unaddressed sources of contamination, provide a policy
framework for managing EPA programs related to ground-
water and strengthen EPA organization for ground-water
protection.
The Ground-Water Protection Strategy was drafted in late
1983 by an Agency Task Force. A draft strategy was
released in January of 1984. State officials, business
and environmental groups, and Federal agencies commented
on the draft strategy. Comments from these groups were
incorporated into the final strategy document.
In discussion of the Agency's approach to unaddressed
ground-water problems, the EPA strategy states that "EPA
will prepare a monitoring strategy... " The strategy
identifies several types of ground-water monitoring:
- ambient monitoring to determine the overall incidence,
extent, and severity of ground-water contamination;
- point of contamination monitoring to detect the occur-
rence and nature of contamination; and
- point of use monitoring to assess the quality of water
at time of use.
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- 2 -
The strategy indicates that EPA will pursue a combination
of ground-water monitoring approaches. Such a combined
approach "may require some additional investment to fill
in data gaps but provides the greatest potential for
meeting monitoring needs by bringing together a broad
multiple interest base of information". In addition, the
strategy states that EPA will conduct targeted surveys of
ground-water contamination from surface impoundments and
underground storage tanks. The strategy concludes that
"EPA will utilize existing monitoring facilities and data
from all available sources (other Federal agencies, State
and local governments, and other organizations) to achieve
the most cost effective and efficient acquisition of
monitoring data".
At about the same time that EPA began development of the
Ground-Water Protection Strategy, the Agency initiated a
major effort to develop monitoring strategies for each
program. Monitoring strategies, which are to be completed
by June 15, will set directions for monitoring and will
identify initiatives needed to improve current monitoring.
The strategies will provide a context for discussion of
FY 1986 budget initiatives in environmental monitoring.
The Office of Water (OW) has drafted an overall water
monitoring strategy made up of a series of monitoring
strategies addressing inland and coastal waters, com-
pliance monitoring, ocean monitoring, and drinking water
monitoring. Other offices have drafted monitoring stra-
tegies which address specific programs (e.g., RCRA,
Superfund, Pesticides). In FY 1985, OW will draft an
overall ground-water monitoring strategy designed to
serve as an unbrella document to guide and assure full
coordination of various EPA program specific monitoring
strategies addressing ground-water, and to identify any
additional areas requiring attention.
B) Ground-Water Monitoring Strategy
The Office of Ground-Water Protection (OGWP) will prepare
the overall ground-water monitoring strategy. The strategy
will be developed in several phases.
Develop Issue Paper
This issue paper is the first step in the development
of an overall ground-water monitoring strategy. The
issue paper identifies key decisions which will set
basic directions for Agency ground-water monitoring
activities. The paper forms the basis for development
of a more detailed strategy document.
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-3-
Revised Ground-Water Monitoring Strategy
EPA program offices will review and update as necessary
(FY 1985) the first round of program specific monitoring
strategies in the Spring of FY 1985. Guidance for this
activity is to be published in January 1985, and revised
strategies are to be submitted by May of 1985. The
OGWP will develop a ground-water monitoring strategy
within this overall Agency process.
In developing the strategy, OGWP will work closely with
other EPA program offices, Regions, States, Federal
agencies, and other interested parties. Every effort
will be made to avoid duplication of activities among
programs or agencies and to build on ongoing ground-
water monitoring activities at EPA, USGS, and other
agencies. A framework and schedule for developing
the strategy is outlined in Section IV of this paper.
FY 1986 Budget Initiatives
The Office of Ground-Water Protection will use this
issue paper as a basis for developing FY 1986 budget
initiatives for monitoring. These initiatives will
be described and discussed in greater detail in the
monitoring strategy. To the extent feasible and
appropriate, OGWP will begin implementing selected
monitoring initiatives in FY 1985.
C) Issue Paper Organization
This issue paper is divided into four sections.
1) Issue Statements
Three key issues which need to be addressed in
order to develop a ground-water monitoring strategy
are described. The issues concern: 1) the overall
objectives of a monitoring program, 2) the relation-
ship of EPA and State ground-water monitoring pro-
grams, and 3) the range of possible areas of
emphasis for internal EPA activities to support
ground-water monitoring program development.
2) Recommended Approach
A general approach to ground-water monitoring will
be recommended as the basis for development of a
strategy. Specific FY 1986 budget initiatives will
be suggested.
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-4-
3) Strategy Development
A framework and schedule for development of the
ground-water monitoring strategy are described.
4) Ground-Water Program Summaries
Brief summaries of existing EPA ground-water
monitoring activities, State monitoring progrcims,
and the monitoring activities of other Federal
agencies are provided in an appendix.
II) Ground Water Monitoring Issues
A) Objectives of Ground-Water Monitoring
Ground-Water monitoring may be undertaken to address
various objectives ranging from determination of overall
incidence of contamination to design of a specific control
program. These objectives are generally accomplished
through one or more of four types of monitoring: 1)
ambient; point of contamination; point of use; and special
project, (see Attachment I). The States, EPA, and other
Federal agencies currently conduct all these types of
monitoring to varying degrees, (see ground-water monitoring
program summaries in appendix). Ground-water monitoring
must also be viewed in the context of other information
about the resource such as hydrologic data, soil types,
climate and uses.
Several issues need to be addressed:
Should EPA explicitly establish a ground-water monitoring
goal and objectives or should the Agency continue to
develop ground—water monitoring programs without a formal
statement of goals and objectives?
If the Agency is to explicitly establish ground-water
monitoring goals and objectives, which of the various
goals and objectives should be given highest priority?
A range of ground-water monitoring objectives and types
of monitoring are described below and several alternative
goal statements (i.e. groupings of objectives) are suggested.
Ground-Water Monitoring Objectives
Ground-Water monitoring may be conducted for a
variety of purposes and to accomplish a range of
objectives.
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-5-
1) Determine overall ground-water quality, estab-
lish quality trends over time, and provide a
record of the incidence of contamination;
2) Identify the characteristics of the ground-
water resource, including background levels
of chemicals in water, nature of flow systems,
and ground-water quality;
3) Assess the extent or nature of contamination
at a particular site or from an identified
source;
4) Identify the source of ground-water contamina-
tion problem;
5) Determine the level or rate of compliance with
permit conditions for a particular site or
facili ty;
6) Determine compliance of ground-water with Federal
drinking water standards or State ground-water
standards;
7) Determine the need for expanded or revised con-
taminant standards;
8) Assess need for controls of various currently
uncontrolled sources of contamination;
9) Determine and design appropriate regulatory or
other control measures or programs; and
10) Evaluate pollution control or treatment systems
to determine effectiveness.
Types of Monitoring
Monitoring activities are commonly grouped into
one of four general categories.
1) Ambient monitoring, conducted by USGS and some
States;
2) Point of contamination monitoring, usually
conducted at a specific site as a part of a
particular program (e.g., RCRA, superfund);
3) Point of use monitoring, such a monitoring of
water at the tap by drinking water supply
systems; and
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-6-
4) Project monitoring, conducted by EPA, States,
and others on a case-by-case basis.
The relationships between the various monitoring
objectives are described in the attached matrix
(see Attachment I). For example, point of use
monitoring is used to determine compliance with
permit conditions and drinking water standards,
and to evaluate control program and treatment
system effectiveness.
Current Monitoring Programs
Descriptions of the ground-water monitoring pro-
grams underway at EPA, in other Federal agencies,
and in States are provided in the appendix.
Directions for Monitoring Strategy
Assuming that the Agency chooses to adopt a formal
statement of objectives as part of a ground-water
monitoring strategy, the objectives identified above
will need to be ranked in priority order, and the
activities and resources addressed in the strategy
will need to clearly support the stated objectives.
The process of defining ground-water monitoring
goals and objectives will require substantive input
from States, and other Federal Agencies. As a first
step in developing the ground-water monitoring
strategy, the office of Ground-Water Protection
would draft alternative goal statements. Several
possible goal/objective statements are suggested
below. Each goal statement involves assigning high
priority to different objectives. Goal and objec-
tive statements, however, are not exclusive; other
objectives would continue to be addressed to varying
degrees.
Improving Understanding of Ground-Water Contamination
- Objectives 1, 2, 3, and 8 ranked highest.
- The Agency will focus on building the scientific and
technical ability to assess ground-water problems and
to develop sound control programs.
Improve Enforceability of Pollution Controls
- Objectives 3, 5, and 7 might be ranked highest.
- Monitoring at point of contamination and project
monitoring would receive more emphasis.
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-7-
Protect Public Health
- Objectives 3, 4, and 6 would be ranked highest.
- Improved and expanded point of contamination and
point of use monitoring would be stressed.
B) EPA Relationship to State Monitoring Programs
Ground-Water monitoring programs are being implemented
in several States and other States are now developing
programs. In developing a strategy for ground-water
monitoring, EPA needs to clearly identify the rela-
tionship between State monitoring activities and the
activities of EPA and other Federal agencies.
A range of approaches to EPA/State relations on the
subject of ground-water monitoring are described below.
Definition of the EPA/State relationship on ground-
water will depend to some degree on the overall goals
and objectives selected for monitoring program. For
example, if assessment of national ground-water quality
conditions and trends is selected as a high priority
monitoring objective, EPA might need to rely more on
State monitoring programs and might seek a greater
degree of consistency or standardization among State
programs.
1) Standardize State Programs
EPA might require each State to develop standardized
or consistent monitoring programs. Such programs
would be built from the standard monitoring ele-
ments in EPA delegated programs and would include
elements designed to support several national
ground-water monitoring objectives. Implementation
of such a program would require promulgation of
regulations, possibly under the Clean Water Act.
2) Require Ground-Water Quality Reporting
EPA might require States to prepare a periodic
report of ground-water quality conditions. The
report would necessitate some basic, standardized
monitoring and might be developed as a supplement
to the State report of surface water quality under
Section 305(b) of the Clean Water Act.
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-8-
3) Facilitate State Monitoring Activities
EPA would not require States to conduct specific
monitoring activities but would work to assist
State monitoring programs. EPA assistance activi-
ties might be in specific response to needs arti-
culated by States or might be designed to focus
State activities in areas which complement EPA
needs/resources. Assistance activities might
include:
— Data management and coordination;
— Standards development and implementation;
— Testing methods for ground-water monitoring;
— Research into innovative monitoring techniques;
and
— Training of State staff in monitoring methods
and monitoring network design.
4) Let State Programs Develop in Response to State Needs
EPA would not try to direct or assist State ground-
water monitoring programs and would focus activi-
ties in ground-water monitoring in other areas
(e.g., greater coordination of Federal monitoring
data). Limited EPA funds could be directed to
other priority monitoring problems.
C) EPA Role — Areas of Emphasis
EPA might expand or initiate program, operational, and
contract activities in a number of areas related to
ground-water monitoring (see below). EPA might choose
to emphasize one or more of these activities or might
support all activities to some degree. A key issue
to be addressed by EPA in development of a ground-water
monitoring strategy is whether to focus limited EPA
operational resources on a specific group of monitoring
program development needs or whether to spread resources
among a wide range of activities. EPA operational
activities which might be addressed to different degrees
degrees in a ground-water monitoring strategy include:
-------
1) Ground-Water Standards
EPA would expand research into standards for
contaminants and increase production of health
advisories and related information.
2) Monitoring Methods/QA/Technology Development/
Equipment
EPA would increase efforts to improve monitoring
methods, measurement techniques, quality assurance
and other monitoring technology. A key objective
of this activity would be to focus efforts on
improving efficiency of monitoring required under
EPA program regulations. The Agency would also
seek to upgrade lab and other equipment related
to ground-water monitoring.
3) Data Coordination/Management/Access
EPA would work to improve coordination of data
collected for existing EPA programs and to improve
coordination of Federal ground-water data (EPA,
USGS, and others). working with USGS which has
similiar responsibilities in this area. To the
extent practical, EPA would work to improve coordi-
nation and provide standard formats and terms for
data collected by States.
4) Assist State Monitoring Programs
EPA would actively work with States to develop an
active program of assistance to State monitoring
programs including making EPA resources available
to meet needs identified by States and to respond
to short term, specific requests.
5) Resource Characterization
EPA would focus efforts on improving understanding
of the ground-water resource including quality/
quantity relationships, aquifer mapping, surface/
ground-water interactions, etc. This activity
would involve close coordination with USGS and
with the States.
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-10-
6) Training
EPA might establish as a priority, development of
hydrology and related skills in the EPA/State work
force. This might involve short term training,
support for course work, and financial support to
related university programs.
7) Compliance/Enforcement Activities
The Agency will focus efforts on development of
those aspects of the monitoring program which
will support compliance and enforcement activities
(e.g. testing methods, and adequate resources).
8) Reporting/Awareness
Ground-Water is a "hidden resource" and pollution
problems are often not understood by the public
until a crisis arises. EPA might expand reporting
of ground-water quality data and work to increase
public awareness of existing/potential problems.
Ill) EPA Recommended Approach
A recommended approach to development of a ground-water
monitoring strategy is suggested below. In addition, a selected
group of FY 1986 budget initiatives related to monitoring are
described.
A) Recommended Approach
Preliminary responses to the various issues posed in this
paper are suggested below and are summarized in Attachment
II.
1) Goals and Objectives
EPA should formally establish ground-water moni-
toring goals and objectives as part of the process
of developing a ground-water monitoring strategy.
Clear goals are necessary in order to provide
direction and relative priority to ground-water
monitoring activities in different parts of the
Agency.
As indicated above, development of a final ground-
water monitoring statement will be the first step
in developing an overall ground-water monitoring
strategy. The OGWP will work closely with other
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program offices, Regions and other groups in
development of. a goal statement and the relative
rankings of other objectives (see Section IV).
As a preliminary recommendation, OGWP suggests
that the Agency give high priority to those objec-
tives and types of monitoring which have greatest
potential to improve enforceability of ground-water
pollution controls. By assigning these objectives
first order priority, the Agency by no means excludes
other objectives.
2) EPA Relationship to State Programs
EPA should, at a minimum, develop a ground-water
monitoring strategy which places the Agency in the
position of assisting States in development of
ground-water monitoring strategies. The OGWP
should also explore the potential with States a
process for consistent reporting of State ground-
water quality data as a basis for National Trend
and status data on contamination and seek comment
on this issue from States and other parties.
3) EPA Role •— Areas of Emphasis
EPA should give greater emphasis to three of the
general internal activities related to ground-water
monitoring: development of standards for contami-
nants in ground-water data coordination, assistance
to States, and compliance and enforcement. Other
activities, of course, are important and would be
addressed to a lesser degree.
B) FY 1986 Budget -- Ground-Water Monitoring Initiatives
(To be added at a later date.)
IV) Management Approach to Ground-Water Monitoring Strategy
The management approach to development of an EPA ground-
water monitoring strategy and a general schedule of key outputs
are provided below.
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A) Management Approach
1) Lead office
The Office of Ground-Water Protection will have
the lead responsibility for all aspects of the
ground-water monitoring strategy and will assure
the involvement of other EPA offices, EPA regions,
States, and other interested groups.
2) Management Oversight
Development of the ground-water monitoring strategy
will be reviewed and assessed by a range of EPA
management and outside interest groups.
The Ground-Water Oversight Committee, made up
of the Assistant Administrators for Water,
Solid Waste and Emergency Response, and Research
and Development and two Regional Administrators,
will review the development and implementation
of the the monitoring strategy at its quarterly
meetings.
The Ground-Water Steering Committee, made up of
EPA program office directors in areas related
to ground-water, will assist in its development
and assure full coordination among programs in
its implementation.
— The Interagency Liaison Group on Ground-Water
will also review the development and implemen-
tation of the ground-water monitoring strategy.
Special emphasis will be placed on assuring
coordination of Federal programs, budget
initiatives, and assistance to States.
— The State EPA Liaison Group on Ground-Water,
made up of national organizations representing
State officials, will also review strategy
development and implementation,
3) Ground-Water Monitoring Work Group
The OGWP will establish a working group to assist
staff responsible for development of the ground-
water monitoring strategy. The work group will
include representatives of EPA program offices,
Regional Offices, and EPA laboratories, and State
agencies. This group will have a major, substan-
tive role in development of each element of the
strategy.
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Because the ground-water monitoring strategy
will address activities of various program offices,
the OGWP will also work closely with the Office of
Management Systems and Evaluation and the office
of Monitoring Coordination, to be created in FY
1985/1986.
B) Key Outputs and Schedule
Key outputs in development of the ground-water monitoring
strategy include:
Final Issue Paper; July, 1984
Inventory Ground-Water Monitoring Efforts — EPA/
State/Federal ground-water monitoring programs;
September/October
— Preliminary Strategy Outline/Draft Goals Statement;
November, 1984
Final Outline; January, 1985
— Ground-water Monitoring Conference; March, 1985
Internal Review Draft Strategy and Implementation
Plan; May, 1985
External Review Draft Strategy and Implementation
Plan; June, 1985
Final ground-water Monitoring Strategy and Imple-
mentation Plan; July, 1985
V) Appendix
(Currently Under Development)
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ATTACHMENT I
GROUND-WATER MONITORING
OBJECTIVES AND APPROACHES
1)
2)
3)
4)
5)
6)
7)
8)
9)
10
Objective
Determine Overall Quality
Trends/Incidence of
Contamination
Identify Resource
Characteristics/Background
Conditions/Flow Systems
Assess Extent/Nature of
Contamination at
Identified Source/Site
Identify Source of
Contamination
Determine Compliance
with Permit Conditions/
Site Specific
Determine Compliance
with Drinking Water
Standards
Determine Need for
Contaminant Standards
Assess Control Needs for
Uncontrolled Sources
Design Regulatory/
Control Programs
) Evaluate Control/
Treatment System
Effectiveness
Ambient
Monitoring
X
X
X
X
X
X
Type of Monitoring
Point of
Contamination
Monitoring
(I)
X
X
X
Point of
Use
Monitoring
(1)
X
X
X
Project
Monitoring
(1)
X
X
X
X
Footnote
1) Data from other types of monitoring can be used to assess trends
in some cases
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ATTACHMENT II
SUMMARY OF GROUND-WATER
MONITORING ISSUES
I) Goals and Objectives
— Should EPA formally establish ground-water monitoring
goals and objectives?
1) No, continue implementation of current program
*2) Yes, establish specific goals and objectives
Which ground-water monitoring goals and related objec-
tives should be given highest priority in a ground-water
monitoring strategy?
1) Improve understanding of ground-water contamination
*2) Improve enforceability of pollution controls
3) Protect public health
11) EPA Relationship to StatePrograms
How should EPA relate to State ground-water monitoring
programs?
#1) Require standard State programs
#2) Require ground-water monitoring report
*3) Facilitate State monitoring activities
4) Let State programs develop in response to State
needs
III) EPA Role — Areas of Emphasis
Given limited Agency resources, which of the following
activities related to ground-water protection should
be given greatest emphasis in the Agency ground-water
monitoring strategy.
*1) Ground-water standards
2) Monitoring methods/QA/technology development
*3) Data coordination/management/access
*4) Assist State monitoring programs
5) Resource characterization
6) Training
7) Compliance/enforcement
*8) Reporting/awareness
*/ Preliminary Recommendation
#/ Explore with States
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